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tGase t:03-cv-02873-MMM^K Document 1 Filed 04/24/03 Rage 1 of 64 PagelD#:l 



SOPHIA STEWART 

P.O. BOX 165153 

SALT LAKE CITY, UTAH 841 16 

Telephone: (801)220-0588 

Plaintiff in Pro Se 




UNITED STATES DISTRICT COURT 
CENTRAL DISTRICT OF CALIFORNIA 



SOPHIA STEWART, 

Plaintiff, 



vs. 



ANDY WACHOWSKI LARRY 
WACHOWSKP . GALE ANN HURD, 
JAMES CAMERON. HEMDALE FILMS, 
JOEL SILVERS, 20™ CENTURY FOX 
PRODUCTIONS. WARNER BROTHERS. 



Defendants. 



Case No: 

COMPLAINT FOR DAMAGES 
AND EQUITABLE RELIEF FOR: 

1. COPYRIGHT INFRINGEMENT 
[17, U.S.C.l; 

2. RACKETEER INFLUENCED 
AND CORRUPT 
ORGANIZATION [R.LC.O.]: 

A. WIRE FRAUD 

B. MAIL FRAUD 
18U.S.C.A.] 

3. SUPPLEMENTAL/PENDENT 
STATE CLAIMS: 
A. UNFAIR COMPETITION 

JURY TRIAL DEMANDED 



Plaintiff. SOPHIA STEWART [hereinafter "PlaintifT' ], respectively, in 
pro se, for her Complaint against Defendants Andy Wachowski [hereinafter "Andy"], 
Gale Ann Hurd, [hereinafter "Gale"]. Hemdale Films, [hereinafter "Hemdale"], 
James Cameron, [hereinafter "James"], Joel Silver, [hereinafter "Joel'*], Larry 
Wachowski [hereinafter "Larry"]. 20"* Century Fox Productions, [fomierly 
Twentieth Centur)' Fox Productions] [hereinafter 20"' Century"], and Warner- BrotJiers — 



[hereinafter "Warner Brother's"], [hereinafter collectively named, 'jDefendants^and- 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



APR 2 8 200^ 



.ORIGINAL 



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each of them, jointly and severally, of which, Plaintiffs information and belief are based, 
among other things, as to her own personal knowledge and upon her own acts and 
conduct, and upon her original writings, documents, papers, files, forms, memorandum(s), 
notes, and scripts, for movie motion picture productions, comic book series, and screen 
treatments, hereinafter alleges, contends and avers, that Defendant's, and each of them, 
have deliberately, intentionally, willfully, knowingly and oppressively, infringed upon 
and violated Plaintiffs protected and secured copyrighted rights and privileges obtained, 
secured and protected, by way of her Certificate of Copyright Registrations [United States 
Copyright Office, The Library of Congress ] 

Plaintiff, having duly received such Certificate of Copyright Registration 
under assigned and proscribed registrations numbers, to wit: Txu 117-610 and Txu 154- 
281, for her literary treatment entitled, "The Third Eye" [February 2, 1983, and the Third 
Eye [Add on Manuscript, (45 pages)], alternatively Third Eye Treatment ( 6 pages) 
[February 6, 1984], and upon documents, papers, files, notes, memorandum's, scripts, 
video(s) recordings, electronic and or magnetic tapes, and reproductions thereof, among 
other writings, [hereinafter "documents"], generated and produced from Plaintiffs 
documents, by the "Defendants", and each of them, for their sole and exclusive 
production, reproduction, formulation, creation, development and proscription into a 
series of movie motion pictures, screen plays, comic books, miscellaneous movie motion 
picture characters and related merchandise, including but not limited to: video 
reproductions, electronic and or magnetic recording tapes, of which directly and 
immediately reveal, refiect and disclose the "Defendants" knowing, deliberate, willful 
and intentional participation in a carefully created and developed fraudulent and deceitful 
plan, scheme and design detailed later in this Complaint. 

Since many of Plaintiff s ''documents", were either purposefully hidden 
from Plaintiff and or destroyed by Defendants, in which to prevent Plaintiffs discovery 
therefrom, and or otherwise unavailable to Plaintiff, under and pursuant to the Privacy 
Act of 1974 . as promulgated under 5 U.S.C § 552a(n(2^. See 28 C.F.R. § 16.96(a> 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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[20011 . and or protected from disclosure under the Freedom of Information Act 
pursuant to 5 U.S.C. § 552('b¥7Kc i and others during the course of their fraudulent plan, 
scheme and design, and that of their deliberate, willful, malicious and oppressive 
Copyright infringement, from Plaintiffs knowledge and information, [despite diligent 
pursuit thereof], Plaintiff believes that discovery from the Defendants, and each of them, 
will reveal additional "documents", that further support Plaintiffs claims for relief 

NATURE OF THE ACTION 

1 . This action arises out of a carefully [fraudulent] plan, scheme and design, 
by which Plaintiff was intentionally, deliberately and willfully defrauded of her 
Certificate of Copyright Registration rights secured and protected to her from 
infringement of her own, original, literary screen treatment, entitled " The Third Eve " 
[Certificate of Copyright Registration. February 2, 1983], as well as the epic science 
fiction manuscript consisting of 45b pages, entitled the ** Third Eve " more appropriately 
identified as "add on Epic Science Fiction Manuscript, alternatively Third Eye 
(Treatment) 6 pages", [Certificate of Copyright Registration, February 6, 1984], in a sum 
in excess of Two Hundred Million Dollars ($200,000,000), plus ten (10%) percent 
royalties from the gross income from the time that Defendants, and each of them, 
deliberately, purposefully, intentionally and wrongfully released to the general purchasing 
public, three (3) separate movie motion pictures, video reproductions, electronic and or 
magnetic tapes, and or other electronic and or magnetic movie motion picture 
productions, entitled: The "Terminator ". " Terminator H ". and the " Matrix ", 
including its prequel and or sequels, and comic book series, which consists of parts of the 
same identical synopsis, theories, character analysis, ideas, illustrations, graphic designs, 
illuminations and names as that of Plaintiff s six (6) page screen treatment and add on 45 
page manuscript. A copy of the Certificate of Copyright Registration Form TX United 
States Copyright Office, Registration Numbers Txu 117-610 and Txu 154-281, is 
attached hereto and marked as Plaintiffs Exhibit "A" and "B", respectively. 

COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 3 



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2. Each of those three (3) individual movie motion picture productions, 
entitled, the Terminator^ Terminator II, and the Matrix, including prequel and sequels, 
comic book series were prepared, created, developed and proscribe by said Defendants, 
and so released for viewing and purchase, by the general purchasing public in movie 
theaters, on video(s) reproductions, and other electronic and or magnetic tape devices and 
by methods of reproduction recordings [D.V.D.], video hand held and stationary units, re- 
runs on national television and syndication television, movies made for television, and 
international/ foreign viewing by the general public throughout the world, by means of 
foreign, international, domestic, interstate and intrastate commerce, [satellite devices, 
computer software via e-mail. United States Postal Service, United States Mail Service, 
mail and wire transfers and communications, publication, distribution] contained 
substantial raaterial parts, components thereof, in fraud, deceit and deception of 
Plaintiffs protected and secured registration of Plaintiff s original six (6) page screen 
treatment and original add on 45 page epic science fiction manuscript, entitled the "Third 
Eye", without the expressed, written or oral, and exclusive permission, consent and 
authorit}' of Plaintiff in violation of Plaintiff s right secured by and under the Copyright 
Act of 1976 . as amended, 17USC §§ IQl et seq. 

3. The ''Defendants", and each of them, were all members of a group of 
movie motion picture producers, directors, officers, authorized agents, benefactors, 
editors, screen writers, movie composers, movie motion picture distributors, and movie 
production Companies, conspirators all, who agreed between and among themselves, to 
engage, act, conduct, and or perfomi and did engage, act, conduct, and or perform and 
are engaging, acting, conducting, and or performing in acts of wrongful deception, 
misrepresentation, fraud and deceit to Plaintiff and that of the purchasing public; 
wrongful deprivation of wrongful deception of Plaintiff s good name and reputation; the 
wrongful deprivation of Plaintiff s right to public recognition and credit as an epic 
science fiction composer, editor, developer, and or creator, screen treatment writer, 
composer, editor and creator of certain copyrighted literary and or artistic work(s) and the 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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owner of the copyrighted original six (6) page screen treatment and original Epic Science 
Fiction Manuscript, consisting of forty-five (45) pages, entitled, the "Third Eye", which 
is the underlying basis, theme, graphic designs, illustrations and composition of said three 
(3) movie motion picture productions, comic book series and screen plays. 

4. Copyright is a form of protection provided by the laws of the United 
States ( Title 17, United States Code ) to the authors of "original works of authorship" 
including: A. Literary works; B. Musical works, including accompanying words; 

C. Dramatic works, including accompanying music; D. Pantomimes and choreographic 
works; E. Pictorial, graphic, and sculptural works; F. Motion pictures and other 
audiovisual works; G. Sound recordings; and H. Architectural works. This 
protection is available to both published and unpublished works. Copyright protects 
"original works of authorship" that are fixed in a tangible form of expression. The 
fixation need not be directly perceptible, so long as it may be communicated with the aid 
of a machine or device. 

5. Defendants, and each of them, conspired among and between themselves, 
and or were part and parcel of the over-all carefully [fraudulent] planned, scheme and 
design in which to form a conspiracy for their joint and several, exclusive monetary, 
financial and beneficial purpose, to either wrongfully obtain, acquire, and secure from 
Plaintiff and or from Plaintiffs authorized agents, Plaintiffs entire protected copyrighted 
original literary works, and or copied substantial material parts therefrom, and or 
components thereof, sequences, scripts, averments, statements and information, 
illustrations, graphic designs, character analysis, screen treatments, making of the Third 
Eye, notes, and 45 page manuscript, which consisted of the Plaintiffs protected/ 
copyrighted original six (6) page screen treatment and the protected copyrighted original 
45 page Epjc Science Fiction Manuscript entitled The Third Eye. 

6. The copying of Plaintiffs protected literary works; artistic works, ideas, 
graphic designs, illustrations, character analysis, scripts, sequences, character analysis, 
ideas, the making of the Third Eye, screen treatment and 45 page manuscript, recreated. 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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promoted, produced, promulgated, disbursed and distributed by Defendants, and each of 
them of the movie motion pictures, entitled the ' Terminator ". "Terminator IV\ and the 
"Matrix'', were specifically, intentionally, deliberately, willfully, and oppressively 
redesigned, recreated, redeveloped, reproduced and distributed throughout the United 
States of America, foreign and abroad, [third (3'"^) world countries], from the character 
analysis, graphic illustrations, draft, synopsis, illustrations, scripts, character analysis, the 
making of the Third Eye, the six page screen treatment, and 45 page Epic Science Fiction 
Manuscript, originally developed, designed, formulated and created by Plaintiff as 
protected, within her copyrighted original six page screen treatment and original 45 page 
Epic Science Fiction Manuscript entitled the Third Eye, which, inter alia, infringed upon, 
and continues to infringe upon and violates Plaintiffs rights and privileges secured to her 
by the laws of the United States of America, as so defined within Plaintiffs filed and 
issued Certificate of Copyright Registration Numbers Txu 117-610 and Txu 154-281. 
without modification, and or change, but for Defendant's name changes of said character 
analysis. 

7. The Defendants recreation, redevelopment, promotion, reproducfion, 
promulgation, distribution, and disbursement throughout the United States of America 
and abroad to third {3'^) world countries, of the movie motion picture entitled the 
"Matrix" by Defendants, and each of them, originally included, but was not limited to 
more than thirty (30) minutes of Plaintiff s original character analysis^ graphic 
illustrations, drafts, synopsis, the making of the Third Eye, and the six page screen 
treatment^ and more particularly, the "introduction", by which, Defendants, and each of 
them, by way of their deliberate, intentional, willful and oppressive fraudulent plan, 
design, scheme, and the redevelopment, production, and recreation, of secondary 
electronic recording devices [D.V.D.] and electronic and or magnetic tape recordings, and 
of supplemental video reproductions and or original video production, and disbursement 
thereof to the general public throughout the world, for their own monetary and financial 
profit, financial gain and beneficial interest, deliberately, intentionally and willfully, cut, 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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removed, omitted and or destroyed from the original production of the movie 
motion picture, more than thirty (30) minutes of the movie motion picture's 
introduction [originally produced for viewing by the general public approximately 160 
minutes, to that of approximately 130 minutes], in an attempt to avoid both civil and 
criminal penahies for Copyright Infringement under Title 17, supra, of Plaintiff s literar>' 
and artistic source works, as noticed and acknowledged by the Federal Bureau of 
Investigation. 

THE PARTIES 

8. Plaintiff Sophia Stewart, a screen treatment writer, composer, editor of 
science fiction scripts, projects, reviews and manuscripts is a citizen and resident of Salt 
Lake City, Utah, having obtained and qualified for a Certificate of Copyright Registration 
of her six page screen treatment and add on 45 page manuscript entitled The Third Eye. 
A copy of the six page screen treatment and 45 page manuscript is attached hereto, 
separately, from Plaintiffs other attached and marked exhibits herein, and made a part 
hereof as though fully set forth at length. 

9. On information and belief, Defendant Andy Wachowski , a producer of 
movie motion picture production, director, comic book writer and a citizen and resident 
of Los Angeles County, California. On information and belief, Defendant Andy 
Wachowski . is the brother of Defendant Larry Wachowski. . On further information and 
belief. Defendant Andy Wachowski' and Defendant Larry Wachowski* placed 
advertisements in a nationwide specialty magazine and or publication and invited writers 
of science fiction epics, screen treatment, more particularly, science fiction documents, to 
submit their literary and artistic works to said Defendants for reproduction and use in 
science fiction comic book series. 

10. On information and belief. Defendant Larry Wachow^ski , a producer of 
movie motion picture production, director, comic book writer and citizen and resident of 
Los Angeles County, California. On information and belief, Defendant Larry 

COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 7 



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Wachowski is the brother of Defendant Andy Wachowski On further information and 
belief, Defendant Larry Wachowski and Defendant Andy Wachowski' placed 
advertisements in a nationwide specialty magazine and or publication and invited writers 
of science fiction epics, screen treatment, more particularly, science fiction documents, to 
submit their literary and artistic works to said Defendants for reproduction and use in 
science fiction comic book series. 

11. On information and belief, Defendant Gale Ann Hurd, is a citizen and 
resident of Los Angeles, California. On infomiation and belief, Defendant is a producer- 
financial backer of movie motion picture productions, and is the former wife/spouse of 
Defendant James Cameron, herein. 

12. On information and belief, Defendant James Cameron is a citizen and 
resident of Los Angeles, County, California. On information and belief, Defendant James 
Cameron is a movie motion picture director, editor, composer,, producer and 

screen writer 

13. On information and belief, Defendant Hemdale Films, is a dummy 
corporation, now defunct, but at all times herein material was a holding company, and 
distribution company for movie motion picture productions for Defendant James 
Cameron and Defendant 20^^ Century Fox Productions, having its principal place of 
business in the County of Los Angeles, State of California. On information and belief, 
Defendant Hemdale Films is a Califomia corporation. 

14. On information and belief, Defendant Joel Silver is a citizen and resident of 
the County of Los Angeles, State of Califomia and is a director of movie motion picture 
productions. 

15. On infonnation and belief, Defendant 20^^ Century Fox Productions is a 
Califomia corporation having its principal place of business in the County of Los 
Angeles, State of Califomia and is principally a movie motion picture production 
company and is a citizen of the State of Califomia 

/// 

COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 8 



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16. On information and belief, Defendant Warner Brothers is a California 
corporation having its principal place of business in the County of Los Angeles, State of 
California and is principally a movie motion picture production company and is a citizen 
of the State of California. 

JURISDICTION AND VENUE 

17. This Court's jurisdiction is based upon Copyright Act 17 U.S.C. §§ 101 et 
seq. and Judicial Code 28 U.S.C. § 1338(a); 28 U.S.C. §§ 1331 and 1332; 15 U.S.C. § 
78aa; 18 U.S.C. 1964(a); 29 U.S.C. § 1132(e)(1); and applicable principles of 
supplemental jurisdiction under 28 U.S.C. § 1367 (a). 

18. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391(b) and 
(d); 15 U.S.C. § 78aa; 18 U.S.C. § 1965; and 29 U.S.C. § 1 132(e)(2). 



BASIS FOR CLAIMS FOR COPYRIGHT INFRINGEMENT AND 
RACKETEER INFLUENCE CORRUPT ORGANIZATION (ACT) |R.1.C,0] 
VIOLATION AMONG SUPPLEMENTAL STATE CLAIMS AND OR CAUSES 
1 9. In early 1 98 1 , Plaintiff, a writer and composer of literary and artistic works, 
caused to be prepared and prepared, on her own, without assistance, supervision and 
control, a six page screen treatment, entitled "The Third Eye", and thereafter, in addition 
thereto, caused to be prepared and prepared a 45 page Epic Science Fiction Manuscript, to 
which she also entitled, The Third Eye. 

20 During the early part of 1 98 1 , Plaintiff further created an original literary 
and artistic source work complex concept that was years before its time and was not 
considered commercially viable in the early 1 980's. A copy of a letter dated June 8, 
1981, from Columbia Pictures Industries, Inc., Richard Berres, Vice President, Director 
of Music, is attached hereto and marked as Plaintiffs Exhibit "C", and made a part hereof 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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as though full set forth at length. 

21. In or about May, 1981, Plaintiff forwarded and delivered a copy of her 
original six page screen treatment to Defendant 20'" Century , by way of Susan 
Merzbach, then a Vice President of Creative Affairs, and at that time a corporate officer 
for said Defendant. 

22. Susan Merzbach, after having read and approved Plaintiffs science fiction 
treatment entitled. Third Eye, verbally contacted Plaintiff, to inquire of Plaintiff, 
whether Plaintiff had more materials, documents, screen treatment, and or scripts that 
Plaintiff had written on Plaintiffs screen treatment in addition to the six page screen 
treatment already delivered. Plaintiff informed Susan Merzbach that Plaintiff was in the 
process of working on a full and complete manuscript of the screen treatment entitled the 
Third Eye, that the actual completion of the manuscript would not be available until the 
Winter of 1983. 

23. On or about the Winter of 1983, Plaintiff was verbally contacted by 
Defendant 20"^ Century , and more particularly, David Madden's office, by way of his 
authorized representative, Valerie Redd, requesting of Plaintiff, Plaintiffs promised 
completion of Plaintiff s Epic Science Fiction Manuscript. 

24. Pursuant to the verbal telephone conversation by and between Plaintiff and 
Valerie Redd, of David Madden's Office of Defendant 20* Century Fox Productions, 
Plaintiff had completed her 45 page Epic Science Fiction Manuscript in or about the year 
of 1984, and thereafter caused to be delivered [through her authorized agent] to said 
Defendant 20"" Century , a full and complete copy of Plaintiff s original Epic Science 
Fiction Manuscript [consisting of 45 pages, plus cover and miscellaneous pages], entitled 
the Third Eye. A copy of a conforming letter dated August 18, 1984, from the office of 
Ester Duffie, Agent to Valerie Redd, David Madden's Office 20* Century Fox 
Productions is attached hereto and marked as Plaintiffs Exhibit "D", and made a part 
hereof as though fully set forth at length herein. 

/// 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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25. On or about July 1, 1985, Plaintiff, by and through her authorized agent, sent 
a written communication to Defendant 20"" Century , attention Lora Lee, Story Editor, 
advising said Defendant of Plaintiff s previous verbal communications with that of Susan 
Merzbach , Vice President of Creative Affairs for Defendant 20'*" Century, and that of 
Plaintiffs previous delivery to Defendant 20"' Century via David Madden's office, of the 
full and complete 45 page Epic Science Fiction Manuscript [hereinafter "Manuscript"], 
entitled the Third Eye. In addition thereto. Plaintiff advised Defendant 20* Century , that 
the delivery of the first Manuscript was by way of return receipt requested, accepted by 
Defendant 20"" Century, but not acknowledgment on the return receipt itself, and that a 
second copy of the original Manuscript was being re-submitted to Defendant 20* 
Century. A copy of the letter dated July 1, 1985 from Plaintiffs authorized agent to Lora 
Lee, Story Editor for Defendant 20* Century is attached hereto and marked as Plaintiffs 
Exhibit "E", and made a part hereof as though fully set forth at length. 

26. On July 10, 1985, Plaintiff received, by way of Plaintiff s authorized agent, 
a written communication from Defendant 20* Century, and more particularly, Lora Lee, 
Story Editor, whereby, Defendant 20* Century acknowledged the receipt of Plaintiff s 
Manuscript. The written correspondence further stated that [paraphrased] "there was 
interest from Fox during a previous administration, I regret to inform you that Fox is only 
allowed to accept submissions from agents who are signatory with the Writer's Guild of 
America. Unfortunately, we cannot make exceptions." A copy of the letter dated July 10, 
1985, from Defendant Fox, by way of Lora Lee, Stor)' Editor is attached hereto and 
marked as Plaintiffs Exhibit "F", and made a part hereof as though fully set forth at 
length herein. 

27. In the Summer of 1986, Plaintiff answered an advertisement in a National 
Magazine, in which Defendant Larry and Defendant Andy [brothers] by way of public 
advertisement, sought screen writers and writing composers of literary works who 
specifically composed, edited, designed, created and developed screen treatments for 
science fiction themes, comic books, writings and or manuscripts, whereby Defendants 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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Larry and Andy wanted to convert and transform said science fiction treatment, 
manuscript, and or screen treatment into the production, publication, and distribution for 
reproduction, publication and distribution of comic book series. 

28. Plaintiff, in responding to the national advertisement published by 
Defendants '"Larry" and "Andy'", sent all of her copyrighted protected original six page 
screen treatment, and that of her 45 page original epic science fiction manuscript entitled 
the Third Eye, including but not limited to the original draft, graphic illustrations, 
character analysis, synopsis, the making of the Third Eye, to Defendants "Larry" and 
"Andy". Plaintiff, on information and belief, avers and alleges that Defendants "Larry" 
and "Andy" had received a full and complete copy of Plaintiff s original six page screen 
treatment, and that of her 45 page original epic science fiction manuscript entitled the 
Third Eye, including but not limited to the original draft, graphic illustrations, character 
analysis, synopsis, the making of the Third Eye, but never responded to Plaintiff. 

29. Plaintiff, after her delivery of her protected "documents" entitled the "Third 
Eye", to Defendants "Larry" and "Andy", did not hear from said Defendants concerning 
her submitted literary and artistic works for years thereafter, when Plaintiff, inadvertently 
discovered that Defendants "Larry" and "Andy" had first produced a comic book series 
entitled the '^Matrix", based and formulated upon Plaintiffs delivered protected 
"documents" to said Defendants. A copy of the comic book script of the "Matrix" by 
Defendants "Larry" and "Andy" is attached hereto and marked as Plaintiffs Exhibits "G" 
and "H", respectively. 

30 In and around the year of 1 999, Plaintiff discovered that Defendants "Larry" 
and "Andy" had stated in writing that they were both the writers and directors of the 
movie motion picture entitled the "Matrix" and had further stated in writing that the 
Defendants "Larry" and "Andy" had hired the professional services of Defendant Joel . of 
Silver Prod\iction to produce the movie motion picture. A copy of the Review for Matrix, 
The (1999) by Ken Price is attached hereto and marked as Plaintiffs Exhibit "I", and 
made a part herein as though fully set forth at length. 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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31. On May 1 1, 1999, via information secured from the internet revealed the 
review of the movie motion picture production entitled "The Matrix", which, inter alia, 
states the following: 

A. MPAA: Rated R for sci-fi violence and brief language 
B- Runtime: USA: 144 / Australia: 1:36 

C. Country: USA 

D. Language: English 

E. Color: Color (technicolor) 

F. User Comments: Christine Fata, Summary: What is the Matrix.. .Oh 
my god, Becky.. "The Matrix (The Wachowski Brothers) Brought to 
you by the writing/directing/producing brothers who also brought us 
"Bound'' and wrote "Assassins'*... . A copy of the movie motion 

picture review of the Matrix by Christine Fata is attached hereto and marked as Plaintiffs 
Exhibits "J" and "K'\ respectively. 

32. On or about May 18, 1999, in review of Yahoo! Movies [internet source of 
"movie information \ fully identifies the "synopsis" of the movie motion picture 
production entitled "The Matrix", and more particularly it's characteristic's: 

A. Genre- SciFi, Action; 

B. Rating-R for sci-fi violence and brief language; 

C. Running Time-2 hrs. 30 min 

D. Release Schedule- March 3 1 , 1999, Nationwide 

E. Directed by Andy Wachwski, Larry Wachowski,. Produced by 
Andrew Mason, Joel Silver. Written by Andy Wachowski, Larry 
Wachowski. Distributed by Warner Brothers. 

F. Play the Trailer-Real Video.., from the Filmxom Screening Room. 
A copy of the Yahoo! Movies is attached hereto and marked as Plaintiffs Exhibit "L" 
and made a part hereof as though fully set forth at length herein. 

/// 



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33 . Plaintiff is informed and believes that years before the actual distribution for 
reviewing and purchase by the general public of the movie motion picture, The Matrix, 
and after Plaintiff had submitted and delivered to Defendants "Larry" and "Andy", her 
protected original six (6) page screen treatment and add on 45 page Epic Science Fiction 
Manuscript, entitled the Third Eye, Defendant's "Larry" and "Andy" , accepted the 
delivered copyrighted literary and artistic source works as their own, as if Plaintiff did not 
exist, and deliberately misrepresented to the general public and that of Plaintiff, as 
Defendant's "Larry" and "Andy's" own creative literary and artistic source works, and 
more particularly states: "Although the Wachowski brothers first gained widespread 
attention and critical accolades when they wrote and directed the dark romantic heist 
thriller, 'Bound,' they had already written "The Matrix" before they began working on 
'Bound'. They sent their completed script to producer Joel Silver." A copy of Page 2 of 
6 pages from internet provider vvmv.atnzone.com/makingthematrix.shtml is attached 
hereto and marked as Plaintiffs Exhibit "M", and made a part hereof as though fliUy set 
forth at length herein. A copy of the cast of The Matrix is attached hereto and marked as 
Plaintiffs Exhibit "N", and made a part hereof as though fiilly set forth at length herein. 

34. On June 28, 1 999, Plaintiff, in writing informed Defendants "Larry" and 
"Andy" of their copyrighted violation and infringement of Plaintiff s source works, and 
demanded from each of them, her due and earned recognition as the writer, composer, 
editor, script producer of the underlying production of both the comic book series and that 
of the movie motion picture production, entitled The Matrix, without success. A copy of 
the letter dated June 28, 1999, from Plaintiff to Defendants "Larry" and "Andy" is 
attached hereto and marked as Plaintiffs Exhibit "0", and made a part herein as though 
fully set forth at length herein. 

35. On information and belief. Defendants "Larry" and "Andy" [from 
infonnation obtained from USA Today], re-wrote from Plaintiffs protected documents 
14 screenplay drafts, supervised about a half-dozen artists who drew story-boards (some 
500 in all) of every scene to persuade Defendant Warner Brothers' top brass to make the 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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film production of The Matrix. A copy of the publication from USA Today is attached 
hereto and marked as Plaintiffs Exhibit "P", and made a part hereof as though fully set 
forth at length herein. 

36. On information and belief, Defendants "Larry" and "Andy", in lieu of 
approaching Defendant 20"" Century, for the actual making of the movie motion picture 
production, "The Matrix", Defendants "Larry" and "Andy" knew and or in the exercise of 
due diligence should have known of the delivery by Plaintiff of Plaintiff s six (6) page 
screen treatment to Susan Merzbach , Vice President of Creative Affairs for Defendant 
20* Century, and that of her 45 page Epic Science Fiction Manuscript to Valerie Redd, 
for David Madden of Defendant 20"^ Centur>', thus choosing to entice and convince 
Defendant \yarner Brothers , to make and distribute the film for the monetary, financial 
and reputable benefit of Defendants "Larry" and "Andy", and their own financial and 
monetary benefit/gain without recognition, screen treatment credit and compensation to 
Plaintiff 

37. On or before April 9, 1999, Plaintiff had caused to be written, a letter to 
Defendant Warner Brothers , legal department, placing said Defendant Warner Brothers 
on notice of Plaintiff s claims of her literary and artistic work on the creation, 
development, writing, composing, editing and production of the six (6) page screen 
treatment and 45 page Epic Science Fiction Manuscript entitled the Third Eye, of which 
Plaintiff had secure copyrighted protection from the United States Copyright Office, The 
Library of Congress and of which the movie motion picture entitled The Matrix, stems. 
A copy of tHe letter dated April 9, 1999, is attached hereto and marked as Plaintiffs 
Exhibit "Q", and made a part hereof as though fully set forth at length herein. 

38. On April 14, 1999, Defendant Warner Brothers, in reply to Plaintiffs 
written notice for Defendant's violations and infringement, totally disregarding Plaintiffs 
protected earned recognition and credits therefor, and the lack of compensation to 
Plaintiff for Defendant's willful, deliberate, intentional and oppressive infringement and 
violation, of Plaintiff s literary and artistic works requested of Plaintiff for a copy of 



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Cafe 2:03-cv-02873-MMM->^ Document 1 Filed 04/24/03 P^el6of64 PagelD#:16 



Plaintiffs book, 'Third Eye'\ among other requested documents, to which Plaintiff 
complied. A copy of the reply letter to Plaintiff from Defendant Warner Brothers is 
attached hereto and marked as Plaintiffs Exhibit "R", and made a part hereof as though 
full set forth at length herein. 

39. Qn May 7, 1999, Pamela Kirsh, Vice President and General Counsel, 
Theatrical for Defendant Warner Brothers, acknowledged receipt of Plaintiff s 
■'documents'' for comparison and investigation of copyright infringement by that of the 
movie motion picture production by Defendant Warner Brothers of 'The Matrix". A 
copy of the letter dated May 7, 1999, is attached hereto and marked as Plaintiffs Exhibit 
''S'\ and made a part hereof as though fully set forth at length herein.. 

40 On June 1, 1999, Jeremy N. Williams, Senior Vice President Deputy 
General Counsel on behalf of Defendant Warner Brothers, forwarded a letter to David G. 
Turcotte, on behalf of Plaintiff, regarding The Matrix and Plaintiff dispute. The letter of 
June 1, 1999, simply denies any substantial similarity between the literary and artistic 
protected works of Plaintiff s and that of the Matrix [inter alia admits some similarity]. 
However, Jeremy N. Williams, admits in said letter the fact that "Regarding your question 
about the source of The Matrix, the answer is simple. There is no 'source work' in the 
sense of some underlying work published in another medium..." [a literary or artistic work 
requires ''source work", of which Defendant Warner Brothers admits to lacking and from 
which Plaintiff alleges source work from her copyrighted literary and artistic work 
stemmed. A copy of the letter dated June 1, 1999, from Jeremy N. Williams is attached 
hereto and marked as Plaintiffs Exhibit 'T", and made a part hereof as though fully set 
forth at length herein. 

41. On February 14, 2001, Plaintiff received a letter from John A. Schulman, 
Executive Vice President and General Counsel on behalf of Defendant Warner Brothers 
legal departrnent, whereby Mr. Schulman states in appropriate part: ''I appreciate your 
zeal about Matrix claim. I invite, again, from you any new or additional evidence you 
have of substantial similarity between your work and the movie The Matrix" 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 16 



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[emphasis added]. A copy of the letter dated February 14, 2001, is attached hereto and 
marked as Plaintiffs Exhibit "U" and made a part hereof as though full set forth at length 
herein. 

42. On information and belief. Plaintiff alleges that according to the article 
entitled Mr. Showbiz Celebrities: James Cameron Biography, dated May 25, 2001, 
Defendant James Cameron "vowed" that he would never again direct someone else's 
movie, Cameron concluded that the only thing for him to do was to write a screenplay 
worthy of his talents. His fever dream bloomed into the script for The Terminator, which 
Cameron eventually sold to producer Defendant Gale Hurd for one dollar and the 
condition that he be allowed to direct the movie-and direct it his way. A copy of the Mr. 
Showbiz Celebrities: James Cameron Bio is attached hereto and marked as Plaintiffs 
Exhibit "V", and made a part hereof as though ftilly set forth at length herein. 

43 . On information and belief, the movie motion picture The Terminator was 
produced by the following production companies, to wit: Cinema 84, Euro Film Funding, 
Defendant Hemdale Film Corporation, and Pacific Western Bank; Distributors were 
Artesan Entertainment [US][Video]; Home Box Office [HBO] Home Video [US][Video], 
Orion Pictures Corporation [US], Thome EMI (video], VCL Communications Gmbh 
[de](Germany, video]. A copy of company credits for The Terminator is attached hereto 
and marked as Plaintiffs Exhibit "W", and made a part hereof as though fully set forth at 
length herein. 

44. On information and belief, Defendant James Cameron, among others, 
including Defendant 20'*^ Century, formulated and created Defendant Hemdale Film 
Corporation for the exclusive purpose of establishing a "dummy" corporation, in which 
to funnel [conduit] monetar>' and financial profits acquired by Defendants James and that 
of Defendant 20* Century, among others, in order to look and appear as if Defendants 
James and that of Defendant 20* Century, and that of their corporation, Hemdale Film 
Corporation, was in the red or negative with respect to net profits for the production, 
distribution and sell of the, movie motion picture production, the Terminator. 



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45. On infon-nation and belief, with the intent to deceive creditors of the movie 
motion picture production entitled The Terminator, Defendant James sold his 50% 
ownership rights to the movie motion picture production entitled, The Terminator to 
Defendant Gale Hurd, for the sum of one dollar [$1.00], [lack of consideration], then, 
thereafter, turned around and married Defendant Gale Hurd, reacquiring a community 
property one/half interest in and to the ownership rights to said movie motion picture 
production, The Terminator in which to avoid and in fraud of creditors. 

46. On information and belief, Defendant Hemdale . intentionally and 
deliberately filed for bankruptcy relief after Defendant James had transferred, "sold" and 
or exchanged his 50% ownership rights to the movie motion picture production The 
Terminator to Defendant Gale, in fraud of creditors, yet, after which, distributed among 
its officers, directors, producers, composers, writers and its own production companies 
including Defendants James and that of Defendant Gale, millions of dollars, not listed or 
reported to the Office of the Unhed States Trustee, Department of Justice, within its prior 
schedule of assets [11 U.S.C. Section 523] 

47. On information and belief, Defendant James, Defendant Hemdale, and that 
of Defendant Gale, conspired between and among themselves, as corporate officers, 
directors and as husband and wife, to deceive and defraud Plaintiff and to deliberately, 
intentionally, willfully and oppressively take money and property rights fi-om Plaintiff. 

48. On information and belief, some twelve ( 1 2) years after Defendant James, 
Gale, 20"" Century, and Hemdale, and others wrongfully infringed and violated Plaintiffs 
protected copyrights to her literary and artistic source works of her six (6) page screen 
treatment and 45 page Epic Science Fiction Manuscript entitled the Third Eye, by the 
production, sells and distribution of the movie motion picture production. The 
Terminator, said Defendants, and each of them, caused the unauthorized production, sell 
and distribufion of the movie motion picture production Terminator II [sequel to The 
Terminator], knowing that at all times herein mentioned the derivatives and or source 
works of original The Terminator movie motion picture production stemmed from 



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2:03-cv-02873-MMM->i»K Document 1 Filed 04/24/03 Pj£]el9of64 PagelD#:19 



Plaintiffs original source work. 

49. On information and belief, the financial backing of the Terminator series 
movie motion picture production, of Terminator II, was by way of Defendant Warner 
Brothers, who had prior knowledge of Plaintiff s claims for copyright infringement of the 
movie motion picture production of The Matrix and the original [first] The Terminator 
and Sony Corporation's Sony Pictures unit. 

50. On information and belief, in production currently, is the movie motion 
picture production, entitled Terminator III, of which those rights to make said movie 
motion picture production are split between a company in bankruptcy court proceedings 
[Defendant Hemdale] and the "former" wife of Defendant James Cameron, director of the 
first two "Tenninator" films. 

51. pn information and belief, Defendant Warner Brothers and Sony have 
contributed a combined $125 million to the production-not including marketing costs- 
though neither will wind up owning the picture. Defendant Warner Brothers agieed to 
pay $50 million for the United States rights plus about that much in marketing costs to 
release to the general purchasing public Terminator III, in the summer of 2003. 

52. On information and belief, Defendant James v/rongfully claims and asserts 
that he, more than 20 years ago, "wrote a 45 page outline for 'The Terminator'", and sold 
the script to production company Defendant Hemdale. On information and belief it may 
be true that Defendant James sold the script to Defendant Hemdale, but it is a false and 
fraudulent assertion and or claim that Defendant James wrote a 45 page outline for The 
Terminator, of which Plaintiff, on information and belief believes that the 45 page 
"outline'' is in fact her protected 45 page Epic Science Fiction Manuscript. A copy of an 
Article published in the Wall Street Journal, Friday, March 8, 2002, is attached hereto and 
marked as Plaintiffs Exhibit "X" and made a part hereof as though fiilly set forth at 
length herein. 

/// 
/// 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



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2:03-cv-02873-MMM-\i*|: Document 1 Filed 04/24/03 Page 20 of 64 Page ID #:20 



PLAINTIFF'S FIRST. SEPARATE AND DISTINCT CLAIM FOR RELIEF 

FOR COPYRIGHT INFRINGEMENT OF SIX PAGE SCREEN 
TREATMENT AND 45 PAGE EPIC SCIENCE FICTION MANUSCRIPT. 
PENDENT qLAlM FOR UNFAIR COMPETITION AS AGAINST ALL NAMED 

DEFENDANTS 

53. Plaintiff here realleges Paragraphs 1 through 52, inclusive, of this Complaint 

54. This action is brought under the federal Copyright Act of 1 976, as amended, 
17 use §§ 101 et seq. This Court has jurisdiction pursuant to Sections 1338(a) and 
1338(b) of the Judicial Code (28 USC §§ 1338(a) and 1338(b). Venue is conferred by 
Sections 1391(c) and 1400(a) of the Judicial Code (28 USC §§ 1391(c), 1400(a). 

55. Prior to the scheduled release date of March 31, 1 999 [The Matrix] 
[Defendants Andy Wachowski- , Larry Wachowski , Joel Silver and Warner Brothers; and 
on information and belief the year of 1984 [The Terminator] and on information and 
belief, the year of 2000 [Terminator II] [Defendants James Cameron, Gale Hurd, 
Hemdale Films and 20* Century Fox Productions], Plaintiff, who then was and ever since 
has been a citizen of the United States and resident of Salt Lake City, Utah, created, 
wrote, edited, developed and established a six (6) page screen treatment and add on 45 
page Epic Science Fiction Manuscript, entitled "The Third Eye". 

56. Plaintiffs above-referenced six (6) page screen treatment and add on 45 
page Epic Science Fiction Manuscript contains a substantial amount of material created 
by Plaintiffs own skill, labor and judgment, and is copyright-able subject matter under 
the laws of the United States. 

57. Between 1983 and 1984, Plaintiff complied in all respects with the United 
States Copyright Act of 1976 and all other laws governing copyright, by applying for 
copyright registration on February 02, 1983 [Remittance Number 11 8848], and again on 
February 6, 1984 [Remittance Number 1 17024], making the required deposit, and 
receiving from the Register of Copyrights a Certificate of Registration Numbers Txu 117- 
610, effective February 2, 1983 and Txu 154-281, effective February 6, 1984, a copy of 



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Document 1 Filed 04/24/03 



which is attached to the Complaint as Exhibit "A" and 'W, respectively and incorporated 
by this reference. Publication and distribution was made with notice in strict and full 
compliance with the federal Copyright Act of 1976. 

58. Since the February 2, 1983, and February 6, 1984, [dates of registrations], 
Plaintiff has been and still is the sole proprietor of all right, title and interest in and to the 
copyright in such six (6) page screen treatment and 45 page Epic Science Manuscript. 

59. After February 2, 1 983, and during the year of 1984, Defendants James 
Cameron, Gale Hurd, Hemdale Films, and 20^^ Century Fox Productions infringed the 
above-mentioned copyright by publishing, producing, creating, distributing, re-producing, 
republishing, recreating and placing on the open market, by way of movie motion 
pictures, video recordings, electronic and or magnetic tapes, soundtracks, movie made for 
television, both domestic and international, world-wide, entitled The Terminator, 
Terminator 11. On information and belief, said Defendant are in production, distribution 
and placing on the open market a sequel movie motion picture production [June, 2003], 
entitled Terminator III [T-3], which was copied largely from Plaintiffs copyrighted six 
(6) page screen treatment and add on 45 page Epic Science Fiction Manuscript, entitled 
the Third Eye. 

60. After February 2, 1983, and during the year of 1984, Defendants Andy 
Wachowski* i, Larry Wachowski Joel Silver and Warner Brothers, infringed the above- 
mentioned copyright by publishing, republishing, producing, reproducing, creating, 
recreating, distributing and redistribution and placing on the open market, a movie motion 
picture production, video recording and electronic and or magnetic tape(s), entitled The 
Matrix and a series of comic books which are based upon Plaintiffs copyrighted material, 
also called the Matrix, On information and belief, said Defendant are in production, 
distribution and placing on the open market a sequel movie motion picture production, 
entitled The Matrix II, which was copied largely from Plaintiffs copyrighted six (6) page 
screen treatment and add on 45 page Epic Science Fiction Manuscript, entitled the Third 
Eye. 

COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 21 



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61 . A copy of Plaintiff s copyrighted six (6) page screen treatment and add on 
45 page Epic Science Fiction Manuscript is attached hereto as Exhibit "Y"; by reason of 
Defendants infringing voluminous bulk and publication method of their movie motion 
picture productions of the Terminator, Terminator II and now Terminator III [T-3] and 
that of the Matrix, video tapes and or recordings and or electronic and or magnetic tape 
reproductions it is impractical to attach copies hereto as exhibits, but copies of the movie 
motion picture productions, video tapes and electronic and or magnetic recordings will be 
made available and exhibited to the Court at all appropriate proceedings. 

62. Plaintiff has notified Defendants, and each of them, in writing and orally on 
numerous occasions that Defendants have infringed and continue to infringe upon 
Plaintiffs copyrights, and Defendants still and continue to so infringe upon the copyright. 

63. After the date of 1 984 [The Terminator], 1 999 [The Matrix], 2000 
[Terminator II], and 2003, [Terminator III (T-3), and continuously since those dates, 
Defendants, and each of them have been publishing, republishing, printing, reprinting, 
selling and distributing and otherwise marketing the movie motion picture productions 
and comic book series entitled, Terminator, Terminator II, Terminator III [T-3] and the 
Matrix, and have thereby been engaged in unfair trade practices and unfair competition 
against Plaintiff to Plaintiffs irreparable damage, which cannot be adequately calculated 
or compensated in money damages. 

64. There is a substantial likelihood that Plaintiff will succeed on the merits of 
this action. 

IIHIIIIIII 

llllllllll 

lllllllll 

lllllll 

Hill 

nil 

III 



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2:03-cv-02873-MMM-'^ Document 1 Filed 04/24/03 [^e 23 of 64 Page ID #:23 

PLAlNTIFF^S SECOND. SEPARATE AND DISTINCT CLAIM FOR RELIEF 
FOR VIOLATION OF RACKETEER INFLUENCE CORRUPT 
ORGANIZATION ACT [R.LC.O.] AS AGAINST DEFENDANTS 
LARRY WACHOWSKIS AND ANDY WACHOWSKIS 

In or About The Summer of 1986, The Scheme Begins: 
Defendants Larry Wachowskis and Andy Wachowskis Solicit Requests 
From The General Public Screen Treatments For Science Fiction Themes, Comic 

Books, Writings and or Manuscripts 

65. Plaintiff herein realleges Paragraphs 1 through 64, inclusive, of this 
Complaint. 

66. In or about the Summer of 1 986, Defendants Larry Wachowskii and Andy 
Wachowski [hereinafter "Defendants"] formulated a plan, scheme and design to obtain 
and acquire other persons work's of "art" [Screen Treatments], including Plaintiffs 
copyrighted "work of art", specifically tailored, created and generated of science fiction 
themes, whereby Defendants planned to convert and transform the acquired science 
fiction treatment, manuscript, and or screen treatment into the production, publication and 
distribution for reproduction, publication and distribution of science fiction comic books 
and following series.. 

67. In response to Defendants national advertisement and requests for screen 
treatments of science fiction themes, Plaintiff, by way of utilizing the United States Postal 
Service, United States Mail Delivery Service, [return receipt requested], specifically 
requested the United States Postal Service to deliver a copy of Plaintiff s entire 
copyrighted screen treatment and that of her 45 page original epic science fiction 
manuscript entitled the Third Eye, including copies of Plaintiff s original draft, graphic 
illustrations, character analysis, synopsis and the making of the Third Eye. 

68. Although Plaintiff had received confirmation from the United States Postal 



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Service of delivery of Plaintiff s entire copyrighted works of art, to Defendants, Plaintiff 
did not receive a "personal" return communication from Defendants as to whether or not 
Defendants would utilize Plaintiffs copyrighted works in their endeavor to publish and 
distribute science fiction comic books and comic book series. 

69. For several years thereafter, Plaintiff continued to perfect other literary 
works of art and continued with her profession as a screen and epic writer of science 
fiction themes. 

70. During those years, Plaintiff did not receive information directly 
Defendant Wachowski' brothers that Defendants had in fact received the copy of 
Plaintiffs 45 page epic science fiction manuscript, six page screen treatment, draft, 
graphic illustrations character analysis, synopsis and the making of the Third Eye [all 
copyrighted]. 

7 1 . Plaintiff was further uninformed and not notified by the Wachowski 
Brothers that Defendants, during those years, were utilizing each and every copyrighted 
material and or material parts and components thereof, copyrighted to Plaintiff in the 
redevelopment, redesign, recreation and making of science fiction comic books and 
comic book series containing Plaintiffs protected copyrighted works of art, for the 
expressed purpose of "publication, dissemination and distribution" to the general public 
for profit. 

72. Defendants, after completion of their "comic books" and "comic book 
series", utilized not only the United States Postal Service, United States Mail Delivery 
Service, for delivery, distribution and dissemination of their completed comic books and 
comic book series, but also utilized telephone and wire services [Interstate Commerce] to 
effect such distribution, dissemination and production. Credits, as published in each and 
every comic book and comic book series disseminated, published and distributed to the 
general public were given and noted solely to Defendants, whereby Defendants failed to 
acknowledge and or give published notice of Plaintiffs literary copyrighted work. 

/// 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



24 



Cage 2:03-cv-02873-MMM-^^ Document 1 Filed 04/24/03 Pafle25of64 Page ID #:25 



Document 1 Filed 04/24/03 F^e 



The Scheme, After Maturity, Begins to Develop And Realize Monetary 

Profits and Notoriety 

73. In and around the year of 1999, Plaintiff first discovered that Defendants 
were wrongfully disseminating, distributing, advertising, promoting, producing, selling 
and displaying to the general public by means of Interstate Commerce, comic books and 
comic book series entitled "The Matrix" which, inter alia contained demonstrably 
material reference and significant material parts, language, description, graphic 
illustrations and character analysis to that of Plaintiff s copyrighted literary works, 
without the permission, consent and or authorization of Plaintiff 

74. On or about May, 1 999, Plaintiff discovered from browsing the Internet 
that Defendants, in addition to distribution, dissemination, production and selling of 
science fiction comic books and comic book series under the "title" of "The Matrix", 
infringing upon Plaintiffs copyrighted literary work, also produced, developed, created 
and drafted from such identified science fiction comic books and comic book series, a 
movie motion picture entitled "The Matrix", containing the same and identical 
copyrighted material references and material component parts, graphic illustrations, 
character analysis and themes as used within their comic books and comic book series 
entitled "The Matrix" that all stemmed and were part of Plaintiff s protected, copyrighted 
literary work. 

75. The scheme carefully planned and designed by Defendants was in 
principal and for the specific purpose of obtaining from unknown science fiction screen 
writers and screen treatment writers, science fiction screen treatments, science fiction 
manuscripts and other similar literary works from screen writers and thereafter, from 
those chosen literary works, by Defendants, deliberately misrepresented and or 
deliberately omitted to represent the true author/writer of the chosen literary science 
fiction screen treatment and science fiction manuscript, character analysis, graphic 
illustrations, and the making of The Third Eye, as their own, in order to not only falsely 
"bolster" their reputation in the industry, but also to make substantial monetary profits 



COMPLAtNT FOR DAMAGES AND EQUITABLE RELIEF 



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e 2:03-cv-02873-MMM-^^ Document 1 Filed 04/24/03 P^e26of64 PagelD#:26 



Document 1 Filed 04/24/03 



therefrom; without demonstrably causing appropriate recognition to the original creator 
and or offering to provide the originator of the science fiction treatment monetary 
compensation; all wrongful activity, conduct and performance was by means of the use of 
Interstate Commerce and to derive an illegal substantial monetary profit from their 
unlawful schenie. 

76. By operation of Defendants carefully planned scheme, Defendants 
obtained millions of dollars from the net proceeds of the sale, distribution and 
dissemination, display, productions, rentals, and lease of the science fiction comic books 
and comic book series entitled "The Matrix'' and obtained, acquired and received millions 
of dollars not only from such wrongful activity, conduct and omissions but acquired, 
obtained and received millions of dollars from the sells, distributions, disseminations, 
rentals, and lease of the movie motion picture entitled, "The Matrix'\ as well as 
receiving, acquiring and obtaining millions of dollars in profit from royalties, movie 
motion picture sales [video and D.V.D], sound and record devices [tape and electronic 
record production], and world wide production. 

77. Each individual sale of the science fiction comic book and comic book 
series and each showing, distribution, dissemination, sale, rental, lease, and syndication, 
among other appropriate display of the movie motion picture, entitled "The Matrix" 
constitutes an independent violation of Plaintiff s copyright privilege. 

78. Plaintiff, because of the enormous extent of world wide distribution, 
dissemination, sells, rental, lease and syndication of the movie motion picture and 
memorabilia(s) from the movie motion picture "The Matrix". Plaintiff is unable to 
define each and every date of violation, but can only surmise that from and after the 
release of both the offending comic books, comic book series and the movie motion 
pictures for viewing, purchase, sales and production by Defendants, such violations were 
had occurring on a daily basis and Defendants continue to be in violation of Plaintiff s 
rights and protection. 

79. From and after the receipt by Defendants of Plaintiffs literary copyright 

COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 26 



e 2:03-cv-02873-MMM-\m Document 1 Filed 04/24/03 Pace 27 of 64 PagelD#:27 



Document 1 Filed 04/24/03 



work, supra, and in conformity with their carefully planned scheme and design, supra, 
Defendants have made millions and millions of dollars all stemming from Plaintiffs hard 
earned recognition re: copyrighted literary work. 

80. Defendants deliberate fraud and deceit on Plaintiff is more fully described 
within the news and promotion articles contained within USA Today Search and other 
appropriate magazines, newspapers and reports. Such fraud and deceit is further 
''published" on the Internet [Interstate Commerce] 

Defendants Deliberately Thwart Plaintiffs Demands For Recognition of Her 
Copyrighted Material and Defendant's Further Ignore Plaintiffs Repeated 
Demands To Cease and Desist From Their Continued 
Misappropriation of Plaintiff s Copyrighted Literary Work 

8L Plaintiff herein realleges Paragraphs 1 through 64, 66 through 78, inclusive, 
of this Complaint, 

82. On information Defendants had actual knowledge and information effecting 
and concerning Plaintiffs copyrighted materials and screen treatment, by way of 
Plaintiffs delivery to Defendant's per Defendant's published request. 

83. On information Defendants at the time of their receipt of Plaintiff s 
copyrighted materials and screen treatment had the specific intent to use Plaintiffs 
copyrighted materials and screen treatment as their. Defendants were had prior 
knowledge and information that copyrighted literary works could not be used and utilized 
as their own without the expressed written consent, permission and authorization from the 
copyright holder, Plaintiff herein, but in using and utilizing Plaintiffs 45 page epic 
manuscript, screen treatment, character analysis, graphic illustrations and the making of 
the Third Eye, Defendants intentionally chose to ignore copyright laws and Plaintiffs 
copyrighted literary works in the production, of both the comic books, comic book series 
and the making of the movie motion picture, the ''Matrix" and follow-up memorabilia. 

84. Plaintiff attempted to mitigate damages by demanding of Defendants, in 



COMPLAEVT FOR DAMAGES AND EQUITABLE RELIEF 27 



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writing, that they immediately cease and desist from the continuation of use and 
utilization of Plaintiff s copyrighted literary works, themes, ideas, screen treatment, 45 
page epic manuscript, but such written and oral demands had fallen upon deaf ears. 

Defendants Larry Wachowski and Andy Wachowski Knew or Should Have 
Known That Plaintiffs Literary Works Delivered to Them Were Copyrighted 

85. Defendant's were in the literary and or artistic business of comic book 
producers. 

86. Defendants advertised in a national magazine or newspaper for persons to 
send to them science fiction screen treatments, science fiction manuscripts and related 
science fiction themes. 

87. Defendants had the prior intent to acquire and obtain science fiction screen 
treatments, science fiction manuscripts and related science fiction themes from the 
general public in which to and from such submitted and delivered science fiction screen 
treatments, science fiction manuscripts and related themes, would create a more viable 
science fiction comic book and comic book series based upon Defendant's "chosen" 
[from submitted/delivered] science ficfion screen treatments, science fiction manuscripts 
and related science fiction themes. Defendant had their employees, officers and agents 
immediately begin to use and utilize Plaintiffs copyrighted literary works as their own. 

88. Defendants did in fact receive from Plaintiff, per Defendants published 
request, a copy of Plaintiff s copyrighted 6 page science fiction screen treatment, science 
fiction 45 page epic manuscript, graphic illustrations, character analysis and the making 
of the Third Eye to their own monetary advantage and reputation in their occupational/ 
professional artisfic field. 

89. Plaintiff, after first discovering Defendant's illegal use and utilization of 
Plaintiffs copyrighted literary works, gave written and oral notice to Defendants to 
immediately cease and desist from their continued unauthorized use and utilization. 

90. Despite such verbal and written demands to cease and desist from 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



28 



e 2:03-cv-02873-MMM-N^ Document 1 Filed 04/24/03 Paae29of64 Page ID #:29 



-'^C Document 1 Filed 04/24/03 



Defendants continued unauthorized use and utilization of copyrighted materials of 
Plaintiff, Defendant still continue to use and utilize such copyrighted literary works. 

9 1 . Such continued unauthorized use and utilization of Plaintiffs copyrighted 
literary works is tantamount to a continuing fraud and violation of Plaintiff s earned 
copyrights. 

Defendants Continue To Hide Net Profits And Earned Contribution From 

Plaintiff 

92. Defendants, from the use and utilization of Plaintiffs copyrighted 6 page 
science fiction screen treatment, 45 page epic science fiction manuscript, graphic 
illustrations, character analysis, and the making of the Third Eye have generated millions, 
and millions of dollars for Defendants and have gain them enormous public and personal 
recognition as science fiction comic and movie motion picture producers, directors and 
"writers", when in truth and in fact all underlying resources, ideas, creativity and thoughts 
for the overall production of science fiction comic books, science fiction comic book 
series and movie motion pictures were that of Plaintiff and Plaintiffs copyrighted 
materials. 

93. Defendants continue to receive millions and millions of dollars in the 
display, release, re-release, syndication, distribution, sales, rentals and lease of such 
science fiction productions, including but not limited to royalties stemming therefrom. 

94. Defendants has neither caused any recognition to Plaintiff as the original 
"writer" of the science fiction comic books, the comic book series and the movie motion 
picture entitled the "Matrix", nor has Defendants monetary compensated Plaintiff for the 
use and utilization of Plaintiff s copyrighted literary works, supra. 

95. Defendants have hided from Plaintiff their ill gotten gain at Plaintiffs 
expense. 

////. 
/// 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



29 



Case 2:03-cv-02873-MMM-VaK Document 1 Filed 04/24/03 Pane 30 of 64 Page ID #:30 



1 



Defendants Larry Wachowski and Andy Wachoski Have Conspired to 

Defraud Plaintiff 

96. Plaintiff discovered that Defendants Lany Wachowski . and Andy 
Wachowski individually and as part of their company, conspired to hire and employ 
Defendant Joel Silver to direct the production of the movie motion picture, the "Matrix'^ 
after Plaintiff had, in writing, notified Defendant Joel Silver of Silver Productions, that 
the underlying basis for the ''science fiction theme" entitled the "Matrix", stemmed from 
material parts, material references of Plaintiff s copyrighted 6 page science screen 
treatment, 45 page epic manuscript, graphic illustrations, character analysis and the 
making of the 'Third Eye", years before Defendants Larry Wachowski^; and Andy 
Wachowski first presented their "revised" "edition" to Defendant Joel Silver. 

97. Despite such notification that the "script" being used by Defendant Joel 
Silver was and stemmed from unauthorized copyrighted literary works of Plaintiff, 
Defendants Joel Silver, Andy Wachowski' and Larry Wachowski under their company 
enterprise continued to produce and direct the movie motion picture entitled the "Matrix". 

Defendants James Cameron, Gale Hurd and Hemdale Films Scheme Was 
Similar to the Scheme of Defendants Larry Wachowskis and Andy Wachowskis 
In the Production of The Movie Motion Pictures Terminator, Terminator 11 

98. On infonnation, Defendants James Cameron, Gale Hurd and Hemdale 
Fims, all participated in a plan, scheme and design to defraud Plaintiff of her copyrighted 
artistic literary works and defraud her of the recognition of achievement and notoriety to 
which she had earned throughout her career, to the monetary and acclaimed recognition 
benefits of Defendants James Cameron, Gale Hurd and Hemdale Films. 

99. On information Defendants James Cameron, Gale Hurd conspired to create 
and incorporate a fictitious business entity known as Hemdale Films. Hemdale Films is, 
and at all times herein mentioned was, a mere shell [straw company] in which to house 
the enormous monetary profits received by Defendant James Cameron and Gale Hurd 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 30 



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3 2:03-cv-02873-MMM->^ Document 1 Filed 04/24/03 P^e31of64 Page ID #:31 

from the production of the movie motion pictures Terminator and Terminator II, and 
deceive not only the governmental taxing authority, from the enormous monetary profits 
acquired and received by said Defendants, but also hiding same from Plaintiff 

100. Both movie motion pictures films were solely based upon the character 
analysis, graphic illustrations and the making of the "Third Eye", together with the 6-page 
screen treatment and 45 page epic manuscript copyrighted by Plaintiff. 

101 . Investigation as to '"criminal charges" for piracy of copyrighted materials 
and theft filed by Plaintiff as against said Defendants, disclosed within the investigation 
by the Federal Bureau of Investigation [F.B.I.] that the two (2) movie motion pictures, 
Temiinator, Terminator Il had exact portions of character analysis, graphic illustrations 
and language utilized by Plaintiffs protected copyrighted literary works without 
modification, change or deletions. 

1 02. Defendant James Cameron, individually and as then part of Defendant 20"^ 
Century Fox Productions, together with his "dummy" corporation, Defendant Hemdale 
Films, like Defendants Larry Wachowski and Andy Wachoski received Plaintiffs 
copyrighted materials, graphic illustrations, character analysis and the making of the 
Third Eye, with 6 page screen treatment and 45 epic manuscript years before the 
production of the movie motion pictures. Terminator, Terminator II.. 

103. Like Defendants Larry Wachowski' and Andy Wachowski',, Defendant 
James Cameron and his company, Hemdale Films, with that of his officers, employees 
and agents used and utilized Plaintiffs copyrighted literary works as their own, without 
monetary compensation and without public recognition. 

104. Like Defendants Larry Wachowski and Andy Wachowski',, Defendant 
James Cameron, Hemdale Films, Gale Hurd, and their employees, agents and officers 
made millions and millions of dollars from Plainfiff s copyrighted literary works. 

1 05 . The use and utilization of Plaintiffs copyrighted literary works by 
Defendant J^mes Cameron and Defendant Gale Hurd was without the expressed and or 
implied permission, consent or authorization by Plaintiff, 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



31 



Cage 2:03-cv-02873-MMM-\iftK Document 1 Filed 04/24/03 Rafle32of64 Page ID #:32 



Document 1 Filed 04/24/03 F^e 



Plaintiff Sophia Stewart Sustained/Suffered Massive Damages From the 
From The Unauthorized Use and Utilization of Her Copyrighted Literary Works. 

1 06. There is no doubt that Defendants, and each of them had made, acquired 
and obtained millions, millions and millions of monetary profit from the unauthorized use 
and utilization of Plaintiff s copyrighted works, including her 6 page screen treatment, 45 
epic manuscript, character analysis, graphic illustrations and the making of the science 
fiction the 'Third Eye", and continued capacity to earn millions of dollars from 
syndication and royalties generated therefrom, including memorabilia, all originally 
stemming from Plaintiffs creativity and ideas. 

COUNT ONE-RICO VIOLATION 

107. Plaintiff repeats and realleges Paragraphs 1 through 64, Paragraphs 66 
through 106 of this Complaint as if fully alleged herein. 

108. Plaintiff is a "person" within the meaning of 18 U.S.C. §§ 1961(3) and 
1964(c). 

1 09. Larry Wachowski ;, Andy Wachowski., James Cameron, Gale Hurd, Joel 
Silver, Hemdale Films, 20"^ Century Fox Productions, Warner Brothers, and their officers, 
agents and employees are persons within the meaning of 18 U.S.C. §§ I961(3)(4) and 
1962 (a)-(d) 

1 10. Defendants Larry Wachowski' , Andy Wachowski James Cameron, Gale 
Hurd, 20"" Century Fox Productions, Warner Brothers, and Joel Silver of Silver 
Productions,, and their employees, agents and officers were a group of persons associated 
together in fact for the common purpose of carrying out the fraudulent scheme described 
in this Complaint; namely, obtaining copyrighted literary/artistic works from Plaintiff, 
among others, and representing to the public that of their own ideas, creations, resources 
and to perpetuate, their unauthorized plan and design for years after the making of science 
fiction comic books, comic book series, the movie motion pictures, the "Matrix", 
Terminator, Terminator II. As a result. Defendants Larry Wachowski !, Andy 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



32 



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2:03-cv-02873-MMM-\m: Document 1 Filed 04/24/03 Page 33 of 64 Page ID #:33 



Wachowski James Cameron, Gale Hurd, 20"^ Century Fox Productions, Warner 
Brothers, Joel Silver, Hemdale Films, named in this Complaint and their agents, 
employees and officers constitute an association-in-fact enterprise within the meaning of 
18 U.S.C. §§ 1961(4) and 1962(a)-(d) [The "Science Fiction Secret Screen Treatment/ 
Science Fiction Copyright Enterprise]. During all relevant times, these Enterprises were 
engaged in, and their activities affected by, interstate and foreign commerce. 

111. In violation of 1 8 U.S.C. § 1962(a)-(d), Defendants conducted and or 
participated in the conduct of the Enterprises' affairs, directly or indirectly, through a 
pattern of racketeering activity. Defendants Larry Wachowski and Andy Wachowski 
participated in seeking through public national magazines, newspapers literary works 
specifically designed for science fiction screen treatments, science fiction manuscripts 
created, designed by others, including that of Plaintiff and obtaining through public 
advertisement such literary/artistic works and presenting same as their own, without 
recognition or monetary compensation to the true author. In the matter at bench, 
Defendants Larry Wachowski and Andy Wachowski obtained Plaintiffs copyrighted 
literary/artistic work and presented such obtained/acquired copyrighted work and 
disguised it as their own, without authorization from Plaintiff. Likewise, Defendants 
James Cameron, Gale Hurd, Hemdale Films, by and through their authorized agents, 
employees and officers of Defendants Warner Brothers and 20'^ Century Fox Productions 
in violation of 18 U.S.C. § I962(a)-(d), Defendants conducted and or participated in the 
conduct of the Enterprises' affairs, directly or indirectly, through a pattern of racketeering 
activity, obtained Plaintiffs copyrighted literary/artistic work and presented such 
obtained/acquired copyrighted work and disguised it as their own, without authorization 
from Plaintiff 

1 1 2. Defendants participated in the Science Fiction Screen Treatment/Science 
Fiction Epic Manuscript Enterprise through these same actions, also by obtaining 
Plaintiffs copyrighted materials under false pretenses. 

113. The pattern of racketeering activity consisted of Defendants aiding and 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



33 



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2:03-cv-02873-MMM-\M< Document 1 Filed 04/24/03 Pafle34of64 Page ID #:34 



abetting the commission of countless acts of mail and or wire fraud, in violation of 1 8 
U.S.C. §§ 2, 1341 and 1343. Specifically, Defendants Larry Wachowski' , Andy 
Wachowski James Cameron, Gale Hard, Warner Brothers, 20"" Century Fox 
Productions, Hemdale Films, and their employees, agents, officers engaged in a scheme 
or artifice to defraud or to fraudulently obtain literary copyrighted property, ultimately 
obtaining money therefrom Plaintiff by means of false or fraudulent pretenses, 
representations, or promises that Defendants were producing such copyrighted materials 
within their authority, rather than obtaining such literary work [copyrighted materials] 
outside their authority. 

114. To execute this scheme or artifice. Defendants Larry Wachowski , Andy 
Wachowski , James Cameron, Joel Silver, Gale Hurd, Hemdale Films, 20* Century Fox 
Productions, Warner Brothers transmitted, or caused to be transmitted by means of wire 
communicatioris in interstate or foreign commerce, and also caused matters and things to 
be placed in any post office or authorized depository, or deposited or caused to be 
deposited the following matters or things to be sent or delivered by private or commercial 
interstate carrier (the '"mailings"): 

(A) Wirings and or mailings of Plaintiff s 6 page screen treatment, between Los 
Angeles and various cities, and states; 

(B) Wirings and or mailings of Plaintiff s 45 page epic manuscript, between 
Los Angeles and various cities and states and to various people and movie 
motion picture production companies, including Warner Brothers and to 
Defendant Joel Silver; 

(C) Wirings and or mailings of Plaintiff s graphic illustrations, character 
analysis, and the making of the Third Eye between Los Angeles and various 
cities and states and to various people and movie motion picture production 
companies, including Warner Brothers and to Defendant Joel Silver; 

(D) The funds transfers by wire between and among several banks located both 
within the state, and different states and foreign countries; 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



34 



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2:03-cv-02873-MMM-^^ Document 1 Filed 04/24/03 Pjae35of64 Page ID #:35 



(E) The secret correspondence between Defendants and each of them; 

(F) Additional mailings and or wiring between Plaintiff and each named 
Defendant from Utah to California. 

1 15. Each Defendant participated in the scheme or artifice knowingly, willfully, 
and with the specific intent to defraud Plaintiff into releasing copies of her copyrighted 
literary/artistic works, including her 6 page screen treatment, 45 page epic manuscript, 
graphic illustrations, character analysis and the making of the Third Eye. 

1 16. These acts of mail and wire fraud constituted a pattern of racketeering 
activity as that term is defined in 18 U.S.C. § 1961(5). Each act of mail or wire fraud 
was executed by the same participants (20"* Century Fox Productions, Warner Brothers, 
Larry Wachowski , Andy Wachowski' , Joel Silver, Gale Hurd, Hemdale Films, their 
agents, employees and officers], by the same method (misrepresentations that each of 
them were either authorized by Plaintiff and or that each were the originator of the basic 
underlying idea). Finally, as a result of each act of mail or wire fraud, the same victim 
(Plaintiff) suffered the same damage (no monetary compensation for her copyrighted 
literary / artistic work and no recognition as to the originator of the underlying idea or 
theme). 

117. As a direct and proximate cause of Defendant's acts of mail and wire 
fraud, and its violation of 18 U.S.C. § 1962(a)-(d), Plaintiff has been injured in her 
business or property right within the meaning of 1 8 U.S.C. § 1964(c), in that Plaintiff has 
lost literary/artistic recognition as the originator of the screen treatment, 45 page epic 
manuscript, graphic illustrations, character analysis and the making of the Third Eye; and 
has further been monetary damaged in the sum in excess of $200,000,000 dollars in lost 
revenue, profits and royalties and has suffered consequential damages from unauthorized 
use and utilization of her copyrighted literary/artistic work. 

////// 

///// 

//// 



COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



35 



. Case 2:03-cv-02873-MMM-' 




Document 1 Filed 04/24/03 Pjae 36 of 64 Page ID #:36 



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WHEREFORE, Plaintiff prays for judgment against defendants for: 

(A) compensatory damages in an amount not now known, but believed to be in 
excess of $200,000, 000 [200 hundred million], trebled pursuant to R.l.C.O. 

(B) punitive damages in an amount to be determined at time of trial; 

(C) Her costs, fees, and other expenses, including attorneys' fees, pursuant to 
18U.S.C. § 1964(c); 

(D) compensatory damages for violation of copyright laws in an amount not 
now known, but believed to be in excess of $200,000, 000 [200 hundred 
million]; 

(E) punitive damages in an amount to be determined at time of trial; 

(F) Her costs, fees, and other expenses, including attorneys' fees 

(G) For such other and further relief as may be just and proper. 



14 



17 



15 



16 



Dated: April 16, 2003 



State of Utah 




So^Wa Ktewart ^ ~7 
P.6. Sox 165153 
Salt Lake City, Utah 
TelephWe: (801)220-0588 



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COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 



36 



Case 2:03-cv-02873-MM|^BK Document 1 Filed 04/24/03^age 37 of 64 Page ID #:37 



RTiRCATE OF COPYRIGHTlfcGISTRATION 




OFFlCIAl 



This certificate, issued under the seal of the Copyright 
Office in accordance with the provisions of section 410(a) 
of title 17, United States Code, attests that copyright reg- 
istration has been made for the work identified below. The 
information in this certificate has been made a part of the 
Copyright Office records. 

REGISTER OF COPYRIGHTS 
Uni(ed States of America 



3^ c 



IRMTX 

UNITED STATES COPYRIGHT OFFICE 
REGISTRATION NUMBER 



TXu " 117-610 



TX 

EFFE CTIVE DATE OF REGISTRATION 

Veb Q 




Month 



Day 



Year 



DO NOT WRITE ABOVE THIS UNE. IF YOU NEED MORE SPACE, USE A SEPARATE COMHNUATION SHEEt. 



TITLE OF THIS WORK ▼ 



PREVIOUS UR ALTEJvNATiVE THXtS V 



PUBLICATION AS A CONTRIBUTION U this work was published as a contribution to a periodical, serial, or collection, give information about the 
collective work in which the contribution appeared. Title of CoUective Work ▼ 



If published in a periodical or serial give: Vblmne ▼ 



A 



Number ▼ 



U«ue Date ▼ 



On Pages ▼ 



NAME OF AUTHORS 



a 



DATES OF BIKTH AND DEATH 
Year Bom ▼ Year Died T 



5TE 

JheJaw, 
jthor* of a 
made tor 
igeneralty < 
iptoyer. 

>{8oeirv 
ona). For 
an of this 
^atwa5 
) to/ htf e' 
L -Yes' in 
lace pro- 
. give the 
>yef (Of 
person for 
1 the wort^ 

uthor' of 
lart, and 
ffie space 
lies ol birth 
jeath blank. 



Was this contribution to the work a 
"work made for hire"? 

□ Yes 
(2 No 



AUTHOR'S NATIONAUTY OR DOMICILE 
\ Domiciled in >^ 



WAS THIS AUTHOR'S CONTRIBUTION TO 
THE WORIC U {he answer to either 

Anonymous? D YesJ3"No oJ tnese questions is 

Pseudonymous? □ Yes ET^o 



see detailed 
instrvjct}or\s 



NATURE OF AUTHORSHIP Briefiy describe nature of the material aeatcd by this author in which copyright is claimed. T 



NAME OF AUTHOR V 



Wis this contribution to the woik a 
Q Yes "work made for hire"? 

□ No 



AUTHOR'S NATIONALITY OR DOMICaE 

Name o» couniiy 

IQtizen of ^ 
Domiciled in ► 



DATES OF BIKTH AND DEATH 
Year Bom T Year Died ▼ 



WAS THIS AUTHOR'S CONTRIBUTION TO " 
THE WORK U me answer to either 

AncnySiOUS? D D oJ these questions 

Pseudonymous? 0 Ye, Q No 'ijtl^wlnt*'""" 



NATURE OF AUTHORSHIP Briefly describe nature of the material created by this author in which copyright is claimed. ▼ 



NAME OF AUTHORS 



DATES OF BIHTH AND DEATH 

Year Born V Lhed V 



Was this contribution to the work a 

_ "work made for hire"? 

□ Yes 

D No 



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Named Country 



* Domidled in 



WAS THIS AUTHOR'S CONTRIBUTION TO 
THE WORK It the answer to either 

Anonymous? □ Yes Q No o* these questions is 
r, . . ^ ^ see detailed 

Ps«J don vmouj? □ Yes □ No rnstrucwons 



NATURE OF AUTHORSHIP Briefly describe nature of the material created by this author in which copyright is claimed. ▼ 



YEAR IN WmCH CREATION OF THIS 
WORK WAS COMPLETED intofm«tion 

JMll>M2i^Year H?*'^-" 



DATE AND NATION OF FIRST PUBLICATION OF THIS PAKHCULAR WORK 

S^nS "IIT^ Month ^ Day ^ Year ^ 

hM b««i published. _. M Nation 



COPYRIGHT CLAIMANT(S) Name and address must be given even if the claimant is the 
same as the author given in space j^f 



TRANSFER If the claimant<s) named here in space 4 are difierent from the author(s) named 
in space 2, give a brief statement of how the claimant(s) obtained ovijncr^hip of the copyright 

fir 



tVED 



Ui 

5^ ONE DEPOSIT RECEIVED 

So 0ZFEB.1Qa3 



TWO DEPOSITS RECEIVED 



2iZ: REMITTANCE NUMBER AND DATE 



OO 



116848 ffcB Z'o^ 



Filed 04/24/0 



This certificate,, issued under the seal of the Copyright 
Office in accordance with the provisions of section 410(a) 
of title 17, United States Code, attests that copyright reg- 
istration has been made for the work identified below. The 
information In this certificate has been made a part of the 
Copyright Office records. 

REGISTER OF COPYRIGHTS 
Unfted States of America 



'age 38 of 64 PagelD#:38 

IRMTX 

UNITED STATES COPYRIGHT Of=FIC£ 



REGISTRATION NUMBER 






1 lu 


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r 


) 

Tvi t y 


EFFECTIVE DATE OF REGtSTRAT10N~ 






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Momh 


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DO NOT WRITE ABOVE THIS UNE IF YOU NEED MORE SPACE, USE A SEPARATE COKTINUATION SHEET 
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PREVIOUS OR ALTERNATIVE TITLES T 



f^/^D Ess {firlL -CA^ /yi^AJu^sChif-i-] 



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Was this contribution to the work a 
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□ Yes 



AUTHOBi^'NATlONALrrY OR DOMICILE 
Namoc 



2. 



No 



OR 



Domiciled in ^- 



WA5 THIS AUTHOR'S CONTRlBUnON TO 
THE WORK If th« answ9f to ttim« 

Anonymous? □ Yes □ No d ihese questkjfw is 

. Pseudonymous? Yes □ No ifi^trvcttens 



NATURE OF AUTHORSHIP Briefl^describe nature of the material cxtated by this author jn whkrh copyright is claimed. ▼ 



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DATES OF BIRTH AND DEATH 
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^ this contribution to the work a 

□ Yes "^^'^ ^ hixe*? 

□ No 



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Name o( country 

iGtiitnof^ 

^^t Domiciled in ► 



WAS THIS AUTHOR'S CONTRIBUTION TQ^ 
THE WORK Jf me answer to aimf 

Anonymous? □ Yea □ >3 olihese quettions TS 

Pseud<^iymous? CLYes □ No ^JJ]^*^^ 



NATURE OF AUTHORSHIP Briefly desaribe nature of the material created by this author in which copyright is claimed. ▼ 



NAME OF AUTHOR ▼ 



DATES OF B 
Year Bom ▼ 



Irth 



AND DEATH 
Year Died ▼ 



Was this contribution to the work a 

_ ^ "woric made for hire^ 

□ Yes 

□ No 



AUTHOR'S NATIONALITY OR DOMICRE 
Mama of Country 
^ < Qtizen of ^ 



* Domiciled in 



WAS THIS AUTHOR'S CONTRIBUTION TO 
THE WORK (f the answer to eimet 

Anonymous? □ Yes □ No d these quetttons is 
« . . ^ ^ "Yw.* see detailed 

. Pseudonymous? Q Yes □ No in$truct>on». 



NATURE OF AUTHORSHIP Briefly describe nature of the material created by this author in which copyright is claimed, ▼ 



0 insinjct)om 
fore cod^piettHQ 
s space. 



YEAR IN WHICH CREATION OF THIS 
WORK WAS COMPLETED TWeWormetton 
in B ^ muat be given 

l^'O P < Year tn aft < 



DATE AND NATION OF FIRST PUBUCATION OF THIS PARTICULAR WORK 

Day ^ Year 

hat bMo put)4l«lMd. < ^^at'«' 



COPYRIGHT CLAIMANT(S) Name and address must be given even if the claimant is the 
same as the author gh^ In space 2.T 

t^Xu^-MjU. ; ^- Y' ^^^^^ 



TRANSFER If the daimant(s) named here in space 4 are di^^erent from the authors) named 
in space 2, give a brief stttement of how the claunant(s) obtained ownership of the copyright 



lU 



APPUCATION RECEIVED 



uja^ONE DEPOSIT HECEIVED 



§ TWO DEPOSITS RECEIVED 



gg REMIHANCE NUMBER AND DATE 



Case 2:03-cv-02873-MMM-VBK Document 1 Filed 04/24/O^Page 39 of 64 PagelD#:39 



June 8, 1981 



Sofia Stewart Productions 
256 South Robertson Blvd. 
Suite 8180 

Beverly Hills, CA 90211 



Dear Sofia, 

Sorry for the delayed response — have been in New York, 
In looking closely at your outline, let me first say that 
I^m not an expert whatsoever in determining what's commercially 
viable for the networks. However, I will give you a personal 
viewpoint and say that while your outline is interesting to 
read, I believe that it is not ''commercially viable". 

In any event best wishes and good luck! 

Cordially, 




Columbia Pictures Industries^ Inc. 



Richard Berres 

Vice Presid<?ni 
piTcctor of Music 




Dick Berres 



DB:ds 




Columbia Plaza, Burbank, California 91505 • 213-954-4045 



Case 2:03-cv-02873-MM]^VBK Document 1 Filed 04/24/03^age 40 of 64 PagelD#:40 



Ester Duffie, Agent 
(915) 949-9208 
2009 Raney 

San Angelo, Texas 76901 
Suite 96 



3353 Ft. Independence Street 
Riverdale, New York 10463 
Suite 14S 



August 18, 1984 



Valrie Redd 

David Madden Office 

Twentieth Century-Fox Productions 

Box 900 

Beverly Hill, CA 90213 



Re: Third Eye by Sofia Stewart-Manuscript 



Dear Valrie, 

Pursuant to your telephone conversation several months ago with Sofia Stewart, 
I am enclosing the above-referenced material for your consideration. 

Sincerely, 



Ester Duffie 



ED/jb 



Enclosure 




Case 2:03-cv-02873-MMM|^BK Document 1 Filed 04/24/03 Page 41 of 64 Page ID #:41 



Verona Russell^Scales, Agent 
(718) 287-8347 

3353 Ft. Independence Street 
Riverdale, New York 10463 
Suite 143 



July 1, 1985 



Lora Lee, Story Editor 

Twentieth Century-^Fox Productions 

Box 900 

Beverly Hill, CA 90213 



Re: Third Eye by Sofia Stewarts-Manuscript 
Dear Ms , Lee: 

In June 1981 Susan Merzbach read these six pages of a science fiction treatment 
entitle "Third Eye" and liked what she had read ...so much in fact, that she 
personally called up my client to see if there were anything more written about 
the subject. Unfortunately at the time my client was busy working on the 
manuscript of her book which wasn't completed until the winter of 83. 

After it's completion, she received a second phone call from Twentieth Century- 
Fox but this time from a David Madden 's Office via Valrie Redd etc. requesting 
the finished products 

I submitted the manuscript on the behalf of my client August 23, 1984 
(Register; Return Receipt), but never received a formal acknowledgment of 
receipt ! 

As per conservation on June 17, 1985, between my client and the secretary 
(Vivian) in your office I am re-submitting this manuscript for your 
consideration- 



Sincerely, 



Verona Russell-Scales 
Agent 



1 1 



VR-S/jb 



Enclosure 




Casi 





July 10, 1985 



Verona Russell-Scales 

3353 Ft* Independence Street, Suite 14S 

Riverdale, NY 10463 



Dear Ms- Russell-Scales, 

Thank you for your submission entitled. Third Eye, which I am returning. 

While I understand that there was interest from Fox during a previous 
administration, 1 regret to inform you that Fox now is only allowed to accept 
submissions from agents who are signatory with the Writer^s Guild of America. 
Unfortunately, we cannot make exceptions. 

Thank you, however, for thinking of Fox. Much luck to you in the future. 
Sincerely yours, 



Lora tee 
Story Editor 




end, 

LL/vcm 




Twentieth Century Fox Film Corporation P.O Box 90C Beverly Hills. CA 9021 3 /2'l3l27 
Cable Address CENTFOX. LosAngeles TELEX 6-74875 



Case 2:03-cv-02873-MM^BK Document 1 Filed 04/24/03^age 43 of 64 Page ID #:43 
The Matrix Page 1 of 2 



[CCoNHC Book — - ] 




The Matrix is not an 
easy film to explain. 
Beneath a story of 
unexpected 
complexity, it is, at its 
core, a film of ideas and it is those Ideas that have 
inspired this project: a collection of stories set in 
the world of the Matrix. 

The stories stand alone. They are not adaptations. 

The contributors are some of the most talented 
artists and writers working in the comics medium 
today. 





(METROPOL), among others. 



They include: Paul 
Chadwick 
(CONCRETE), Neil 
Gaiman 

(SANDMAN), Bill 
Sienkiewicz 
(ELECTRA 
ASSASIN), Harian 
Elison (I Have No 
Mouth and I Must 
Scream), Steve 
Skroce (GAMBIT), 
Michael Kaluta 
(BOOKS OF 
MAGIC), Geof 
□arrow (HARD 
BOILED). Poppy Z. 
Brite (LOST 
SOULS), Larry and 
Andy Wachowski 
(BOUND), Ted 
McKeever 



The stories work without seeing the film and run a 
wide spectrum of types, from action to 
contemplation to frightening, much like the film 
itself. 



http://www.whatisthematrix.coni/cmp/comic.html 



5/27/99 



Case'!2:f)y-cv-62873-MM^VBK Document 1 Filed 04/24/0^^396 44 of 64 Page ID #:44 




http://www.whatisthematrix.com/cmp/ted_08.html 



5/13/99 



g)PStgtrtg^g(M)fgB||^BK Document 1 Filed 04/24/03^age 45 of 64 PafQ^DlftflS 



Matrix, The (1999) 

reviewed by 
Ken Pierce 



The following review is supplied by www.dvdfuturexom 

Directors: Larry & Andy Wachowski 
Writers : Larry & Andy Wachowski 
Producer: Joel Silver 

Studio: Warner Brothers 

Characters : 

Keanu Reeves - Neo 

Laurence Fishburne - Morpheus 

Carrie-Anne Moss - Trinity 

Joe Pantoliano - Cypher 

Hugo Weaving - Agent Smith 

Review: Well, The Matrix has to be one of the most difficult reviews Fve ever had the 
pleasure of writing. I say ''difficult", because it's an incredibly difficult movie to critique 
without giving away too much of the plot. Like so many movies which have intricate, 
weaving plotlines, a lot of the fun is watching the twists and turns unfold. As such, I will not 
go into a long explanation of what The Matrix is about, but will instead talk about some of the 
hits and misses for this fihn. 

First and foremost, I expected a lot from this fihn. I should say out front, though, that the 
filmmakers' previous effort, Bound, did not impress me at all. I thought it was pretty standard 
fare, and suffered from a plot Une which dragged intensely at some points. Still, though, there 
was certainly a dramatic flair, and a touch for those things odd. This is what excited me about 
The Matrix, I didn't expect it to be standard fare, and I was right. 

The Matrix is a movie that almost everyone can enjoy. I've heard some older critics 
complain that the soundtrack is too loud, but I found it fit the look and feel of the movie 
perfectly. This movie has the same art director as Dark City, and it shows. It also shares more 
than a few plot elements with Dark City, but goes places Dark City shouldVe gone. The 
Matrix owes a lot to Dark City and Terminator, but in most ways expands upon the ideas 
presented in those films, I would have to say that The Matrix is much better than Dark City, 
and (here is a huge compliment) as good as The Terminator. This movie will be a science- 
fiction/action film classic. 



First the pros: The art direction, set design and special effects are outstanding, As is 
Carrie- Ann Moss as Trinity, Hugo Weaving as Agent Smith and Joe Pantoliano as Cypher. 
The action sequences are incredibly well filmed, and the movie clips along at an incredible 
pace. Warner Brothers gets bonus points for not giving away the whole frdaJcin' movie in the 
trailer. Most of the "COOL!" shots in the trailer take place in the first three to five minutes of 
the film (!), there*s a LOT more here than the trailer shows. The plot line is beautifully 
intricate, and keeps you guessing at various points in the movie. It has a tendency to go left 
when you expect to go right, except when you start to expect it to go left, then it goes right. 
Great stuff! 



http://us.imdb.com/ 



1 



5/26/99 



Case 2:03-cv-02873-MM 
Matrix, The (1999) 



BK Document 1 Filed 04/24/03 ^aae 46 of 64 Page ID #:46 



MPAA : Rated\ for sci-fi violence and brief! 
Runtime: USA: 1 44 / Australia: 1 36 
Country: USA 
Language: English 
^Color: Color H ecbnice 
Sound Mix: DTS / Dolby Digital / SDDS 
Certification: USA:R / Australia:M / Italy:! / Nonv ;ay:lS 
^ — - - — — - - --^ = 1 



Pige2of3 




User Commentsi: 



Christine Fata (thekeek@aol>coiii ) 
Scottsdale^ Arizona 



Date: 11 May 1999 

Summary: What is the Matrix.., oh my god, Becky.. 



The Matrix (The Wachowski Brothers) - 
Brought to you by the 

writing/directing/producing brothers who also 
brought us "Bound" and wrote "Assassins" 
for Richard Donner. Starring Keanu Reeves, 
Laurence Fishbume, Carrie- Anne Moss and 
Joe Pantolione. What is the Matrix? If s very 
difficult to accept a concept that is so far fi-om 
normal thought as to be nearly 
incomprehensible. Even more difficult, I 
imagine, to incorporate such an unimaginable 
concept into your everyday realm, and be told 
to forget everything you know and understand 
as reality. Add to that, the responsibility of 
being told that you are the new Messiah, the 
next Saviour, the only hope... THE ONE. 

Well, rd say "forget it" and probably cave. 
Or, Td face this new adventure with open 
eyes, an open mind and hope it^s not TOO 
terrible. For this adventure is an amazing one. 
The story is tried and true - Good vs Bad, it 
always is. But it's a gripping story with 
incredible... no, better than incredible... more 
like Un-Freaking-Believable special effects 
and fight scenes. I was entranced. Not once as 
I watched did I utter the phrase "Oh, I am SO 
sure". Not even once! I perceived the fights as 
real, accurate, believable. Tm very critical 
from watching Hong Kong action and their 
hyper-dramatic martial arts fight scenes, but 
here, we are led down a path gently focusing 
our eyes to what the filmmakers wish us to 
believe and the concept placed in my mind 
made all the amazing fight scenes jaw- 
dropping. 

It's all like that. The unbelievable is now not 
only believable, but a working part of the 
universe as we know it. Or maybe not. 
Confused? Oh you will be.. You WILL be.. 
And then, like an epiphany., or maybe a two 



http://us.imdb.com/Title?0133093 



5/18/99 




^3^7 of 64 P^9|eip^i7 



Beauty where you see this close-up of Liv Tyler^s hand goir^ right underneath her 
panties - it's like she's kneading bread, practically! We stood up and screamed, 'I 
can't believe Tm watching this!" Larry called the bisexual author Susie Bright, a friend 
and technical advisor on Bound. She said: "That was your first experience of 
homophobia. Makes you mad doesn't it?" 

The Wachowski Brothers are now hard at work on their next project, Matrix, a 
science-fiction yarn based on "the script that nobody understands", as Larry puts it. 
"The studio made us put an intro on it that basically explains the plot." adds Andy. 
"At the first story conference, our guy was going [adopts Mr Magoo voice], like, 'Now 
I know this is something very cool; I just don't know why,.. Could you just explain 
what it's all about?'" At which point the phone rings and Larry takes a call from studio 
hotshot Joe) Silver in the next room. As Andy sits chatting, interview oveir, his 
brother's voice can be heard, rising in amplitude and pitch. "I don't believe it.... They 
said what? They can't do that!" 

Directing, the Wachowski Brothers agree, is more difficult than they had envisaged. 
Still, says Andy, should they ever need to go back to carpentry, they've made some 
great contacts. "There's lots of refurbishment to be done in Hollywood." 

interview by Andrew Smith, appeared in The Guardian newspaper on Friday February 7th 1997 



Home t WhaVs New | Lowdown | Gallery | Review s | Interviews; | Lnternat[onal | Links 



Back t o the interv ie ws P age 





http://www.users.dircon.co.uk/'-'muttley/bound/interviews/bwachint 



5/18/99 



Case 2:03-cv-02873-MM^VBK Document 1 Filed 04/24/03^age 48 of 64 Page ID #:48 



CINEMA 



Popular Metaphysics 

In The Matrix, the Wachowskis make a hit film 
out of the Bible, cyberpunk and higher math 



By RICHARD CORUSS 



BUNCH OF GUYS AT A MANHATTAN 
plex watching The Matrix. Carrie- 
Anne Moss kicks some 'droid butt, 
makes a streetwide leap from one 
building top to the next, then crash lands 
through a small window. "The bitch is 
bad" one of the guys opines, "Go, girl!** 
Then Laurence Fishbume shows up as 
Morpheus— a morphing Orpheus, a black 
White Rabbit, an R.-and-B. Obi-Wan 
Kenobe, a big bad John the Baptist, a Gan- 
dalf who grooves; every v^e guide from 
literature, religion, movies and comix. 
Though he's in a dark room in the dead of 
night, and as if he needed to be more cool, 
Fishbume is wearing these teeny black 
shades. Another guy at the plex says ap- 
provingly, "Those glasses aiefabulousr 

To deliver a futurismo fashion state- 
ment and a can of whup-ass in the same 
movie— this is smart filmmaking. Larry 
and Andy Wachowski, the Chicago*bred 
brothers who wrote and directed The 
Matrix, are smart in a way moviegoers 
love and Hollywood moguls cherish; the 
picture, shot in Austraha for $63 million, 
had the year's strongest opening week- 
end and pulled in a robust $50.7 million 
in its first nine days. The film's producer, 
Joel Silver, says the boys have a sequel in 
mind, and cannily adds, "The more suc- 
cess the movie has, the more willing 
they'll be to write it down." Suddenly 
Larry, 33, and Andy, 31, are giving Peter 
and Bobby Farrelly (There s Something 
About Mary) competition as the hottest 
brother act in tov^. 

But the Wachowskis, whose first di- 
rectorial effort was the seductive femme- 
noir drama Bound, have deeper fish to fry. 
"We're interested in mythology, theology 
and, to a certain extent, higher-level 
mathematics," says Larry, "All are ways 
human beings try to answer bigger ques- 
tions, as well as The Big Question. If 
you're going to do epic stories, you should 
concern yourself with those issues. People 
might not understand all the allusions in 
the movie, but they understand the im- 
portant ideas. We wanted to make people 
think, engage their minds a bit." 

And blow their minds a lot The film 
posits that life as we know it is a comput- 
er simulation: it is, Morpheus says, "the 



world that has been pulled over your 
eyes" by some creepezoid machines that 
look like spidery octopi. Who can free a 
mankind that doesn't know it's enslaved? 
Morpheus believes the cybermessiah is 
Neo (Keanu Reeves), a computer hacker. 
Early in the film Morpheus offers two pills 
to Neo. Take the blue one, you wake up 
and remember nothing. Take the red pill, 



tion. The Matrix plunders Blade Runner 
and The Terminator: bad machines, 
grungy rebels and rain, rain everywhere, 
even indoors. It invokes the kung furiosity 
of prime Jackie Chan and the heroic blood- 
shed and long coats of John Woo movies; 
the Hollywood' Hong Konglomeration 
has never meshed so suavely as in this 
film's fight scfenes and wire-work aero- 
batics. Never 5een the mega-imaginative, 
ultraviolent Japanese cartoons known as 
anime (Akirai Ghost in the Shell}? Now 
you have— in whirling live action. 

Those are just the movie references. 
The Wachowskis, both dropouts from 
good colleges (Larry from Bard, Andy 
from Emerson), want to weld classic ht, 
hallucinogenic imagery and a wild world 




"you stay in Wonderland. And I show you 
how deep the rabbit hole goes." 

Naive viewers may think The Matrix 
is just a cool way to pass the time while 
sitting in the Phantom Menace waiting 
room. They should think again, breathe 
deep, get strapped in for a brain-popping 
trip. The Matrix is a careering cyberride 
vidthout the headset, a virtual master- 
piece. Every other movie out there is the 
blue pill. This one is the red. 

An anthology of dystopic science fic- 



of philosophical surmises to pop culture. 
The Bible meets Batman; Lewis Carroll 
collides with WiUiam Gibson; Greek and 
geek mythology bump and run. Hell, you 
may find string theory in The Matrix, 

As the children of a businessman and 
a nurse^ the boys created comic books, 
and the obsession continued into their 
20s, "Jack Kirby comics interested us," 
says Andy. "We liked the idea of punch- 
ing guys through brick walls and over- 
the-top action like that." But they con- 



TIME. APRIL 19, 1999 



Case 2:03-cv-02873-MM|^-VBK Document 1 Filed 04/24/0^ Page 49 of 64 PagelD#:49 



11^ 



CINEMA 



nected as well with older, more revered 
sources, "The Bible seeks to answer a lot 
of relevant questions for man/' says Lar- 
ry, "In the film we refer to the story of 
Nebuchadnezzar; he has a dream he 
can't remember but keeps searching for 
an answer. Then there's the whole idea of 
a messiah. It's not just a Judeo-Christian 
myth; it also plays into the search for the 
reincarnation of the Buddha/' 

The search-the quest-informs 
Greek myths ("We have Orpheus and 
Morpheus in the film/' says harry) as well 
as Alice*s Adventures in Wonderland: "It's 
a story about consciousness," says Larry, '^a 
child's perception of an adult's world. The 
Matrix is about the birth and evolution of 
consciousness. It starts off crazy, then 
things start to make sense/' It can also be 
read as a variant on Gibson's Neuro- 
mancer, the 1986 cyberpunk classic about 
a computer cowboy on the run. "It'd be 
near impossible to make a movie out of 
that," says Larry. 'We knew the way to 
make it relevant was to turn what we view 
as the real world into a virtual reality." 

And now, for extra credit: theoretical 
mathematics. The lads became fascinated, 
Larry says, "by the idea that math and the- 
ology are almost the same. They begin with 
a supposition you can derive a whole host 
of laws or rules from. And when you take 
all of them to the infinity point, you wind 
up at the same place: these unanswer- 
able mysteries really become about 
personal perception. Neo's jour- 



ney u affected by all these rules, all these 
people trying to tell him what the truth is. 
He doesn't accept anything until he gets 
to his own end point, his own rebirth/' 

Great, guys, but is Joe Popcorn sup- 
posed to carry a Matrix concordance in 
his head? "We wrote the story for our- 
selves and hoped others would pick up on 
it," says Larry. "Every studio we showed 
it to thought no one would understand it. 
We told them it would be complex and 
dense, but we were also going to shoot the 
best action scenes and coolest computer 
graphics ever. Even if audiences didn't 
get all of the references, we knew they'd 
at least have a good time with the visuals." 

Kind of like Star Wars, eh, where the 
kids came for the laser show and stayed for 
the course in Joseph Campbell? WelU 
maybe not The Force is good, fun stuff," 
says Larry. "I grew up on those movies. 
But we were hoping to do something a lit- 
tle more sophisticated with The Matrix.'' 

Comparisons aside, the brothers have 
shown they can make a science-fiction 
epic that both probes and throbs. George 
Lucas' May tricks are a month away, but 
Andy and Larry have proved that right 
now the/ re the big Wachowski.— iiep<irted 
by Jeffrey Ressner/Los Angefes 



mmmx 

CONCORDANCE 



Finnegans Wake has its skeleton 
key, Gatsby its Otff Notes. A film as 
densely allusive as The Matrix needs a 
box score, with Wachowski footnotes: 





Mythology 



W iff the Sccf|ltllf«^jiM^ 

'^e have Orpheus and Morpheus En heret'' Larry says. TTie 
Odyssey^ with Ks prophetic oracle, was a touchstone text. 



brWomierlaiifl 

Japanese Anime 
and Hong Kone^u 

Gyberptfiik 
Noveb 

Theoretical 
Mathematics 

Psycboiogy 



fftthbrn^onAScMilbigiq^lfioii^^ if^ 
tiie VWifte Raiibtt is bliclCf apcl the rdbbit tioi o ii#ioitefc 

In Asian cartoons and \hm action, flying is the only way to 
travel. Here characters waJk up walls and leap-frog buUdhigs. 

As In Msimnanoer^ ow hem enters « vMual m 
pitshisciimdrvaBainstdaricloniiofartllkMM^^ i 

The boys read 77ie Tao of Physics and (Mel, Esclter, Bac/t. 
Where do physics and metaphysics meet? At The Matrix. 

Archetypes fa hyperspacew Urrn ^lMjrth^^ 
to old ciilturei^ and future ones^'^The movie b 




BOURGtolS BUSS: Watson and Bale 
make a |g;ood case for grownup pleasures 

Family Values 

Who needs sex, drugs or 
rock 'n roll when you 
can have Emily Watson? 

HE HAS IT all: "CREATIVE" JOB, SEN- 
iible wife, pretty child, starter 
home in Metroland, the generic 
tiame for London's middle-class 
suburbia, Chris (Christian Bale) also has 
something he doesn t need: his best 
friend from the swinging '60s, a wander- 
ing poet named Toni (Lee Ross), who 
lurches back into his life in the late 70s 
to taunt and ten\pt him. The taunts are 
about the road not taken-abandoned 
careet in photography, abandoned girl- 
friend (sweet, sexy Elsa Zylberstein) 
froiti his years in Paris. The temptation 
is to return to youthful irresponsibility. 
Uh-oh— another wistful study of 
quiet desperation among the symbol 
manipulators, another examination of 
how the anarchic spirit of the '60s got 
sold out But this adaptation of Julian 
Barnes* first novel, by director Philip 
Saville and screenwriter Adrian Hodges, 
has some good things going for it They 
understand that it isn't politics, Pop Art 
or drugs that would come permanently 
to haunt the memories of that brief, lost 
time for people like Chris. It's the sex, 
stupid. And the freedom that era offered 
to pursue it across all sorts of formerly 
formidable barriers. 

There's honesty and energy in tlie 
film^s flashbacking pursuit of that 
thought. But Chris' lasting luck is his 
wife Marion. Emily Watson plays her as 
a kind of dream nanny—knowing, ironic, 
tolerant of his erotic nostalgia and not as 
prini as she looks. She, and Metroland, 
finally make a good, subtle case for the 
bearable weightiness of middle-class 
beiilg, for the higher morality of mud- 
dling through. i -By f^cftard Sdthkel 



76 



TIME, APRIL 19, 1999 



\ 

\ 



Case 2:03-cv-02873-MMI^BK Document 1 Filed 04/24/03^age 50 of 64 Page ID ^ 
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Genre: 

SciFi, Action 



Rating: 

R for sci-fi violence 
and brief language 

Running Time: 

2 hrs. 30 min. 

Release Schedule: 

March 31, 1999 
Nationwide 

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Synopsis: 

In the near future, a computer hacker named Neo (Keanu Reeves) 
discovers that all life on Earth may be nothing more than an 
elaborate facade created by a malevolent cyber-intelligence, for 
the purpose of placating us while our life essonce is "farmed" to 
fuel the Matrix's campaign of domination in the "real" world. He 
joins like-minded Rebel warriors Morpheus (Laurence Fishbume) 
and Trinity (Carrie Ann Moss) in their struggle to overthrow the 
Matrix. 

Production Notes 

Read what others have to say. 
Write your own review! 

Cast and Credits: 

Starring: Keanu Reeves , Laurence Fishbume, Carrie- Anne Moss, 
Hugo Weaving, Joe Pantoliano 

Directed by Andy Wachowski, Larry Wachowski. Produced by 
Andrew Mason, Joel Silver. Written by Andy Wachowski, 
Larry Wachowski. " Distributed by Warner Bros.. 

Film ^jos - Credit List 

Play the Trailer: 

* Reaiyideo...from the Film.com Screening Room 



Copyright © 1994- 1 999^^01100 !, hic. All rights reserved. 
Questions, comments, suggestions? Send us feedback 
...Opinions?...Take it to chat or message boards 




http://movies.yahoo.comymovies/guide/the_matrix.html 



5/18/99 



Say the brothers, "We believe passionately in the importance of 
mythology and the way it informs culture." 



Their ideas were further refined through their exploration of the 
developing world of the Internet. For writers and filmmakers who have 
come of age after the emergence of personal computers, the online 
universe is both an exciting and fertile new avenue of creative 
expression, and a ubiquitous and somewhat sinister element of 
contemporary life. The Wachowskis explored both sides of the 
technological revolution when they created The Matrix. Say the 
Wachowskis, "We began with the premise that every single thing we 
believe in today and every single physical item is actually a total 
fabrication created by an electronic universe." The brothers 
developed this disturbing thought into an intricate story that blends 
action, stylish imagery and a complex consideration of what actually 
constitutes reality. 




and acquired the property. 



Although the Wachowski brothers first 
gained widespread attention and critical 
accolades when they wrote and 
directed the dark romantic heist thriller, 
"Bound," they had already written 'The 
Matrix" before they began working on 
"Bound." They sent their completed 
script to producer Joel Silver, who has 
explored alternative futures in such hit 
movies as "Predator" and "Demolition 
Man." He was immediately fascinated 



Explains Silver, "The Matrix' is a very complex story; it takes place in 
the future but it is told in the present, Larry and Andy have spent 
years fine-tuning the script so the audience can accept and 
understand this story. Very rarely do you find filmmakers who know 
so exactly what they want and are as decisive as these two guys." 



The filmmakers' plan for the movie was to combine their provocative 
dramatic premise with images, effects and action that would truly 
astound audiences, and fight scenes using Asian cinematic 
techniques of wire fighting that would break new ground with their 
intensity and style. Further, the Wachowskis sought out cutting-edge 
camera techniques to enable them to render entire sequences in 
ways that action films have never been seen before. 



"The Matrix" is a movie with a lot of 
ideas, but it is unmistakably a rousing 
action-thriller at the same time. Many of 
the fight scenes in the story dramatically 
demonstrate the evolution of Neo's 
character and the power of his 
adversaries. The style of these physical 
confrontations grows directly from the nature of The Matrix. 

Explain the Wachowskis, "Once you start dealing with a digital reality 
you can really push the boundaries of what might be humanly 
possible. So if characters in The Matrix' can have information 
instantaneously downloaded into their heads, they should, for 
example, be able to be as good a Kung Fu master as Jackie Chan," 

This premise offered the Wachowski brothers a chance to work in 




http ://www. atnzone.com/makingthematrix .shtml 




5/27/99 



Case 2:03-cv-02873-MM^VBK Document 1 Filed 04/24/0^'age 52 of 64 PagelD#:52 
The Matrix Page 3 of 4 



^ see it for yourself. - (281 kb) 



THE CAST OF THE MATRIX 




Keanu Reeves 



■ X 



JVIORPHKUS 
Laurence Fishburne 




Carrie- Anne Moss 



ALrbNl SMilH 
Hugo Weaving 




^■4 



Marcus Cheng 



CYPHER 
Joe PantoHano 




SWITCH 
Belinda Mcclorv 




Julian Arahanga 




Matt Doran 




http://www.o2craftxom/scifidu/niatrix.html 



^ ^ 



5/20/99 



Case 2:03-cv-02873-MM^BK Document 1 Filed 04/24/03^age 53 of 64 PagelD#:53 



June 28, 1999 

Andy & Lany Wachowski 
Warner Brothers 
4000 Warner Blvd. 
Burbank,CA 91522 

Re: ""The Third Eye'V'The Matrix" 

Dear Sirs: 

This letter is to inform you that I have given key evidence and the name of a Witness to the 
Federal Bureau of Investigations, on June 10, 1999, for criminal prosecution. 

I have submitted my original draft , illustrations and character analvsis pertaining to "The Third 
Eye" to you to make into a comic book. I discovered years later that not only have you used my 
epic material for the comic book "The Matrix," but you have also adapted from chapters, 
illustrations, and characters of my published book (published^November 23, 1983) into a 
screenplay called "The Matrix." 

I have contacted you numerous times asking you to pay for the stolen material and have not 
received a re])Iy from you. However, I have received several letters from Warner Brothers 
asking for evidence to use against me as a cover-up. 1 have since discovered why. You leave me 
with no choice in the matter. Since you have been living off of me, so to spe&k, for a number of 
years now, I sec no course other than to take this matter to the Federal authorities. 

You have committed a white collar crime, (willful copyright infringement is a federal crime and 
perjury a felony), a crime I feel would not have been discovered if you did not continue this 
unauthorized activity. 

Gentlemen, I will not let this matter go unresolved... you will pay me a settlement or restitution 
for the stolen material. Either way, I will be paid for the work I have done, f have given you 
every fair chance to comply and I am prepared to have you prosecuted to the fullest extent of the 
law. This is a very serious matter; a federal investigation will uncover other activities. The FBI 
took my information due to copyright thefts. Washington needs a "high profile case" to be made 
an example of! I suggest you get some criminal lawyers if you do not intend to pay... Timing is 
Everything! 




Sincerely, 



Som Stewart 



P.O. Box 165153 

Salt Uke City, UT84116 

(801)575-8387 




Case 2:03-cv-02873-MM^VBK Document 1 Filed 04/24/03^age 54 of 64 PagelD#:54 

Mystery duo illuminates dark 'Matrix' Page 2 of 3 

million/ " says Pantoliano, who plays a featxu^e role in The Mat 
"They didn't see the light of day for 365 days." 




Actually, the Wachowskis, who less 
than a decade ago were ruiming a 
small construction business in their 
native Chicago, spent 5 1/2 years on 
The Matrix . They wrote 14 
screenplay drafts and, in an almost 
unheard-of move, supervised about a 
half-dozen artists who drew 
storyboards (some 500 in all) of every 
scene to persuade Warner Bros.' top 
brass to make the film. 

"You talk to people and they always 
ask, 'Why are action movies so dumb?' 
" Larry says. "We hope people are 
more interested in a more intelligent 
approach. We hope they are not just 
interested in what we call McDonald's 
movies, the standard you-know-what-you-get" films. 

Preparation was key. Along with storyboarding, the Wachbwsk 
insisted the film's principal actors — Reeves, Laurence Fishbur 
Carrie-Anne Moss and Hugo Weaving — take four months of 
intensive martial arts training. 

Larry and Andy also envisioned an innovative style of special e 
The brothers worked on comic books before selling their first 
screenplay (the Sylvester Stallone- Antonio Banderas bomb 
Assassins , of which Larry says, "We tried to get our nanie tak 
that film"). They wanted to bring the Japanese style of animatio 
called anime to live action. 



Action hero: in the sti-p t 
'The Matrix, * Keanu Reeve 
plays Tltomas Anderson, a 
anonymous computer 
programmer who becomes 
buUet'dodging Neo, pursue 
mysterious agents (WB). 



The anime perspective would allow a camera to follow an obje 
motion and shift the view while other objects remain still. 

For example, the Wachowskis wanted to show a bullet speedin 
motionless character while moving the audience's viewpoint. 

They considered a "rocket camera" that would go 300 mph. But 
Andy, "the insurance people didn't like that." 

Eventually, with the help of visual-effects maven John Gaeta, t 
brothers worked out an intricate system that in some scenes use 
high-tech cameras and a laser-guided tracking system. 

Their determination to get it just right has earned praise fi^om th 
they work with. 

The Wachowskis, says Matrix producer Joel Silver, "are very 
similar to (writing/directing team) the Coen brothers. Tliey bot 
know what they want, they really do it together, and they know 
they have to do to get it done." 

The Wachowskis may know what they want on screen, but they 
typically anti-Hollywood when asked about the fiiture. Will the 
do another movie? 

http://www.usatodayxom/ Y ^'^ ^'^^ 



Case 2:03-cv-02873-MM^BK Document 1 Filed 04/24/0:^age 55 of 64 PagelD#:55 

Warner bros, Leqal dept. p^obox i65^ sait Lake city, ut, 84116 

^ 801 575-8387 



April 9, 1999 

4000 Warner Blvd. 
Dear Sir or Madanri: 

I recently spoke with your office about the movie "Matrix "April 1, 1999.This movie Is a unauthorized 
derivative work based on my book called 'Third Eye". \ wrote this book in May 1981TXU 1 17-610 and 
added to it November 1983TXU 154-281. Many pioducers. production companies, editors, lawyers 
comic-book illustrators had access to this material. I have a list of all people involved. I was attending 
use ( University Of Southern California ) at the time, i ov/n all rights to this book. Since I never 
authorized you to do any work , it follows that you infringed upon my copyright by doing so. 

This letter is to demand that you immediately cease and desist from selling or showing of this 
movie. In addition , I demand to be reasonably compensated for the use of my book and all work that 
have been copied and sold. Please respond to this letter by May 1 3, 1 999 . 



Sincerely, 




Sofia Stewart 
AuthorA/'^/ filer 




916 POl-'Ol.RPR IS 99 11;30 



Cage 2:03-cv-02873-MIV^VBK Document 1 Filed 04/24/O^Page 




age ^#^ 6 



Vice Pftijdcr\i and Gensrat Ccun 
Thcjtrtcii 



US. Mail 



Vy^RNER BROS. 
(618) 954-2331 



April 14, 1999 

Sofia Stewart 
P.O. Box! $5 1 S3 
Sslt Lake City, Utfih 
84116 

rc: MATRIX** 
Dear Ms, Stewart, 

I am responding to your April 9, 1999 letter to the Warner B:o5. Legs! depaitment 
concerning the above-referenced matter. In order to evaluate your claim that IIIE MATRIX 
infringes your copyright in and to your book enlilled **Third Eye", 1 vvill need tile following 
information and documents: 

( 1 ) a copy of your book Third Eye" ; 

(2) copies of the copyrif^ht registration and Writers Guild registraiion, if any; 

(3) evidence of access (including date submission) by V/amcr Bros, or anyone else 
associated witli THE MATRIX to your boo.k; 

(4) an analysis of the similarities l)etv\'c^n THE MATRIX and "Third Eye"; and 

(5) any o\her informj^tion you believe wc/jW j-clcvsnt for us to coiisiucr in evaluating 
your claim. 



As I'm sure you understand, Warner Bros, lestrvcs aii of its rights and remedies in this 



meaner. 




Very truly yours, 

/ 



PK./CS?. 



Case 2:03-cv-02873-MM 




BK Document 1 Filed 04/24/03 ^aae 57 of 




e ID#:57 



Pamela Kirsh 

Vice President and General Counsel 
Theatrical 



4000 Warner Boulevard 
Burbat^k, California 91522 
(818) 954-2331 
Fax3 (818) 954-3490 



WARNER BROS. 



By U.S. Mail 



May 7, 1999 



Sofia Stewart 

P.O. Box 165153 

Salt Lake City, Utah 84116 

re: '^Third Eyc^' 
Dear Ms. Stewart, 

1 received the materials you sent in connection with your claim that ''THE MATRIX'' 
inrringcs your work ''Third Eye''. We are now able to conduct an investigation and evaluation of 
your claim and will respond to you in more detail as soon as that process is complete. Please 
understand that may take a few weeks. In the meantime, if you have any additional information 
which you believe will substantiate your claim, please fonvard it to my immediate attention. 




PK/csa 



cc: 



John Schulman 
Jeremy Williams 




A Time Warner Enienainmenr Company 



Case 2:03-cv-02873-MM^BK Document 1 Filed 04/24/03^age 58 9 



Jeremy N, Williams 
Senior Vice President 
Deputy General Counsel 




age ID#:58 



WARNER BROS. 

4000 Wnmcr Boulevard 

BurbankXalifomia 91522 

(818) 9?4'2096 

Fax: (8 J 8) 954-3503 

E-Mail: jercmy_williams@wamerbros.C( 



June I, 1999 

Via Fax (801 364 4867) and First Class Mail 

David G. Turcotte 
1101 South 800 East 
Salt Lake City, Utah 84105 

Re. The Matrix — Sofia Stewart 

Dear Mr. Turcotte: 

Your May 21, 1999 letter to John Schulman and Pamela Kirsh has been referred to me for 
reply I appreciate the chance to express our view of the matter to you in the hope of resolving 
it without litigation 

I can best do that by referring you to my May 19, 1999 letter to Ms. Stewart. You didn't 
mention that document your letter, so in case you have not seen it I enclose a copy for your 
review In the letter, 1 explain in some detail why her claim lacks merit. Obviou$ly, there is no 
point in repeating that detail here. I will just summarize our reaction to the claint as follows: 

1 . The Third Eye and The Matrix hardly resemble each other. They are very diflferent stories, 
differing in setting, characters, and plot. The few elements of similarity that exist fail way 
below the level of protectible expression, and even those elements are treated very differently 
in the two stories. The legally required infringement standard — substantial similarity — is not 
approached here. 

2. Ms. Stewart has offered, and we have found, no evidence whatsoever of access to her 
unpublished work As you know, courts in copyright cases will not accept mere possibility or 
speculation as a basis for establishing access. Without credible evidence of access, there is 
simply no case 




A Tirtic Wamcr Entertainment Company 



Case 2:03-cv-02873-MMM||BK Document 1 Filed 04/24/03 ^ge 59 of 64 PagelD#:59 
David G. Turcotte .-/"iSffeix. 



Regarding your question about the source of The Matrix, the answer is simple. Thdre is no 
^'source work" in the sense of some underlying work published in another medium. The film is 
based on an original screenplay, and the screenplay contains an original story created by its 
authors. 

One other point is worth emphasizing here. In your letter, you state that a "simple denial" of 
liability "without supporting documentation" will not satisfy you or your client. That statement 
implies that we have the burden of proving that we did not copy your client's work. That is a 
legal theory that neither we nor any court will accept. On the contrary, your client must prove 
copying, and, as noted, we have seen no evidence that even suggests it. 

As I hope Ms. Stewart will confirm, we have treated her claim seriously and respectfijlly. But 
based on everything we have seen to date, there is no merit in this claim. That leaves us no 
choice but to defend against it, and if necessary we are prepared to do so. We hope, however, 
that upon objective review of the evidence, you and Ms. Stewart may come to th6 conclusion 
that there is no basis here for legal action. 



Page 2 




Sincerely, 




Jeremy N. Williams 



Enclosure 



cc: Pamela Kirsh, John Schulman 



Case 2:03-cv-02873-MM 



BK Document 1 Filed 04/24/03 ^ane 60 of 64 Page ID #:60 




John A. Schiilman 
Executive Vice President 
and General Counsel 



WARNER BROS. 



rebmary 14, 2001 



400Cl\X'amer l>ouIevard 
Burbnnk, California 9\522'OOn 
mi) 95'M223 Kix. (818) 954-4768 
K-Mail: john„sch ulman@vvarncrbros.com 



Ms. Sofia Stewart 

PO Box 165153 

Salt Lake City, UT84116 



Dear Ms. Stewart: 

I appreciate your zeal about your Malrix claim, J invite, again, from you any new 
or additional evidence you have of substantial similarity between your work And the movie 
The Matrix. 1 also welcome any evidence you have of access by the movie's creators to your 
work. Such would enable us to evaluate your claim more fully, and might cause us to reach a 
different conclusion. To date, we have corresponded with you and your attorney, Mr. David 
Turcottc, whom wc have not heard from since last summer. I thought tliat Warner Bros, had 
pointed out to you and your representative the reasons for our disagreement with your claim. 



Sincerely, 



/ 




JAS:hjl 




A ^imc Wamcr Enrcrtainmcnt Company 



M(Ca^§y^^J?vQ^§tel1W^ 04/24/03^age 61 of 64 ^^\^ Ski 



State University at Fullerton. He disappeared into his pfiysics 
studies, then restlessly switched to English, and ultimately dropped 
out. He nnarried a waitress and worked variously as a machinist, a 
truck driver, and a school-bus driver; in the evenings, he nurtured 
his artistic ambitions by writing stories and painting. 

The next pivotal juncture in Cameron's evolution as a director came 
in 1977, when he saw Star Wars for the first time. It was exactly the 
movie he had dreamed of making since watching 2001, and it 
inspired him to finally get busy. With no formal training whatsoever, 
Cameron started to fool around with different moviemaking 
apparatuses, tinkering with lenses and beam splitters, and even 
building a dolly track in his living room. He made innumerable trips 
to the library at USC, where he pored over doctoral dissertations 
about various projection and special effects techniques; he made 
photocopies of everything he could and took careful notes on the 
material he couldn't. "My wife thought I was crazy," he later 
recalled. "The guy who used to like to smoke dope and go to the 
river and drink beer and drive fast cars, all of a sudden had gone 
psychotic on her. She was afraid of me." 

For his first project, Cameron and a friend financed and filmed a 
ten-minute short from scratch, using models, sets» and mattes they 
constructed themselves. With no more experience to his credit than 
that fledgling offering, he was hired at Roger Corman's New World 
Pictures, where he was named production designer and second 
unit director by his second assignment. Galaxy of Terror After 
watching him shoot a scene involving close-ups of a disembodied 
arm covered with maggots — Cameron convinced the reluctant 
grubs to writhe using a hidden electrical charge — two Italian 
producers offered to let him direct a film called Piranha II: The 
Spawning. 

The earnest twenty-five-year-old Cameron eagerly accepted the job 
and headed to Jamaica, only to discover that his crew was 
comprised primarily of Italians who spoke no English. The film's 
producers refused to let Cameron see any of his dailies, and they 
kept telling him that his work was "all shit." Distraught, the rookie 
director flew to Rome after production wrapped and demanded to 
see the film. Rudely informed that the final cut had been prepared 
without his input, Cameron broke into the studio's editing room 
using a credit card, found the print of Piranha II, and taught himself 
to use the unfamiliar Italian editing equipment to secretly re-cut the 
entire movie over the course of the next several weeks. 

Sick, hungry, and flat broke, Cameron stayed in Rome until the job 
was done. On one of those dark days, he awoke from a particularly 
vivid nightmare with the idea for a story about an invincitile robot 
hit-man. Vowing that he would never again direct someone else's 
movie, Cameron concluded that the only thing for him to do was to 
write a screenplay worthy of his talents. His fever dream bloomed 
into the script for The Terminator, which Cameron eventually sold 
to producer Gale Anne Hurd for one dollar and the condition that he 
be allowed to direct the movie — and direct it his way. 

Made on a mind-bogglingly minimal budget of $6.5 million, The 
Terminator scored a roaring financial victory and firmly established 
Cameron's reputation as both a writer and director of undeniable 
talent. For Hurd and Cameron's second collaboration, the sequel to 
Ridley Scott's Alien, 20lh Century Fox rolled out the red carpet. 



http://mrshowbiz.goxom/celebrities/people/jamescameron/bio.htiTil 5/25/01 



Case 2:03-cv-02873-MM^BK Document 1 Filed 04/24/03^age 62 of 64 Page ID #:62 





, V/SA" 



NextCard Internet Visa - Apply Now 




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Top 
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Photo I IMDb j Browse i Independent 

Gnllenes I Recommends I IMDb I Filn'j 

Pacje 4 of 34 



Company credits for 
Terminator, The (i984) 

Production Companies 

« Cinema 84 

o Euro Film Funding 

e Hemdale Film Corporation 

» Pacific Western 

Distributors 



o Artisan Entertainment [us] (Video) 

o Home Box Omce (HBO) Home Video [usj (vicieo) 

• Orion Pictures Corporation [usj 

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» VCL Communicotions GmbH [dej (Germany, 
video) 

SpeciaJ Effects 

• Fantasy 11 Film Effects 
o Stan Winston Studio 

Opticals 

. Ray Mercer & Company 

Extras casting 

. Ciinstal Blue Casting / 

eft * 

Robots supplied and operated by 



,'-irtp://us.imdb.com/Companie5?0088247 



3/? 1/01 



/fQ2a7)3-bWI|*MBK DocwimieoitSL Filed 04/24/03^age 6 

THE miiL STREET JOlfflfiL. 



63 of 64 Pa^n])#:63 



VOU CCXXMX NO 47 ♦ * 



The Producers 

The Terminator Is 
Back— After Millions 
Spent to Get ItStarted 

In Sequd'Citzy Hollywood 
InstaDment 8 Wks a Bet 
Studios Couldn't Elesist 

Sehwuzcncgger Woib Out 



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l»e wiO*. OUsrt »ai ltd*. 8:il Cka 
Ikoi to tn? It btoua tfaay ■ksJ dia lajaa 
cQtBil' Ml UlUk ctoD KQitts met 
hoOM Mtort be jmrd toto ivadal (xje- 



tree vaUar wto ie raw 4 teat0tM eB» 
itotoei to atrnm VkfWa a tix»- 

FkBiannitof^4i' 



TODATfi CONTINTS 



« iJwjLjiiUfc awe ei 




du] ay wfit cni* epdt, id. 



otnw k ainu)0«; SkdlBD 



uaSKkH mart MM CU&vk 



Wfa shfngtonW tre 

A ^wdi] \Mty RqxsT Fkm 
The VBbl Street Jautsan 
Cip bm l Burcsu 

jwwgrduiji ji » to O a»*a»ad 

* neBmeSEtotekRS^ bum 
to g^W tM flKkl 2K> biH to iqtl. 
Mikaptoi t ittoT emtti tot Covn- 
tet litofat cfika OO wfA 

^ 9iBtR2o.(aDiididikMStatoitt 
lOta fer a OMoa ton* too. 



Bto CWntok Oand, Utor ariw lb» 
WUia tfeif 'cseked (te Luu 
tttb'r kp«dtit, vaf «tt 10 fli^en t» 
- ioier M |lv. Wlto (etoaes atoD- 

.__ m bfiki. bsm kdA • ftoti «A 

TOttt toe nfirite tria. 

ftttlte/M^Bkcfid/btfaBbSv 
varitor neifel^ M «» OGD- 
aeai^eeai. 

DOOM niUWT utottoiM to w 



Ufk^ WMed a CkfM JO) 
Ak mi ta ylMd^atoei ttk OatamD 
- igH Ik a M« ly tolttv 

9U em Ui tUl ^kad^f etopoau Uk- 

toiKy od Mtocdteg a of 

QOQft vndd 



Otn^aidai 
hlOktotf e( 



»aMH4ACQc mmpa iP:iotoi 

VttMi, MtoVk Cop jtorttoid , deSecik. 
n« vctHom «Mrito kr tsk. 

OCP Li iki i*nr cf -ta aaiv#i 
tan aJto." MOM to toe toiMMM ie> 
If* el Ittrk ItotoM aafl Ito ■aai-toatb'' 
tbi mlk «M dOP ttoff«kir Mtoai 
PmMevi MXtoKj; a ktotodcto tofote 
Of M entoW-k^ Mtoew rfn}- 

kM r>i»t- 

ItoWltf lttfMi %piHta to^yaar 
tod atS mIiUui kfai sifialtD Aekfldt 




m taks ^eUdeUtol aspBlia . 
TEeeeto^ kgtf e kk ^^OdKlto 
d»'k«i«toi. 



AMxr^leb 

TlteacT laa«enr orrtodold, H I 
fAkdekf M IfaJkOtoeemoinrievw 

at * Iftiyli OOP W 



■MttotoiiaoMsedeodl: -7to»t« 
tUar we A) to dekl Mb te redaatom to 
BB tte peafte to Jno nan It tBcti on 



rtoe OMtol kneeeM ted Xnjr 
«iMtoo«iMi«riitottetoto „ 
Batff aer TiuvwCiifcto leeutty kA- 
tEkOnoeq^tot. JOk* Hem b av)* 
fctt Mtflkf vlto UtttedOeWa. Ttov 



plod' KrH|M Ukuf 

Kafw toe bM Weit nlmlfiltfiioeB tA 
dan Jmn fuati-Witf tttoo eeoy 
fn^ eed taetof v^oMt-a^uMd 
^knod tnvetor* nift to Ok kMo ai Ik- 




BiTtnyobe^^ 

dMl^iMit pw it i p a. k 1 
die all Qdd» Wl k "toca 




QSEOinmi Bkkxrms: 
itnoooMmvoR— 
Ik Ttaddka vbue 



riflwH aed stoorftMi Hiowlme vtlb ^ 



(qfbi w*H !k( 

opobte^ipo^vUt tree bod uklwe. 

to (M oony. B« kMO IN tkto- 
bA^miEB oeiieoo eokatooi torvewtr 
raedtSed pw>i~ ^ ' ' 
ivdiB 



SouT Sign-Off 
A Final Ptension Move 
Soils High Standing 
Of Ibp European CEO 

AfiB's Bimev^ Col}ected 
|87^an.11)eaDucked 
Questions fVcxn^BoBid 

Spur tD Corporate Openr»ss 



Q18tU-(Mr 4k0 Pkit fvv yetn. 



9kn*lb kai eaed Ua Sim 

"iS 



A ed*ieeied On apf4l}dlCMit of V|pa^ 
oBocjia dmwt teedr to dtt 

' — - - -- — Jb 




DTka a af Mr. I 
• U hd»ffld»ei 
Btfi tf^iift.toi 

brM itoai iM ka dMdaatkd tor em 
Q«k a dicida. Ud by ov (ttMMe dtno- 
tko ^ovd 




tiTP» fc aet tti pay- 1 ^ 

ene^t^Biaaa^toi. — — — = 



J Ibdf tDowbdn 

k^ tMlft Bvwtbkd da<f<d«Sr 
■kMi H «tfk ao oaotiiBed to 



jorf « tte 
mteoaO klS'a 

EtTtWrniMttor 
teaia* deer tost 



m^Ma paaetaik At k « 
ad Uto a|taf« 



, vto«] PdnktoHtouid toe Gvear utto 




OtotoM vkb Oe eeUepea ef Bimi 
Onu be fiknMkkflkIr b esbotoatoc 
roMto i^toB tf fiiutoku iierywlu 
to itlJl JU^i J m man atatf oR'i^fK 
cMvokkKtOD kK e^Xf aaaddvi atom. 
Kteodtm wd laMfnekt oKicrB in- 
dtt fte M noed w MOe 9taipe^ 
nta <ivniiirtn toerO, ipiOin i 
may to akkietoa|l»- 
■ Hiirii e CMp eJtt 
OK iwoH soMM to ikkkroafiUtiB vkji 
Od itat cbO MM aiik bbfim 
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•d u X Birdff b tiM fl^taL 
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UtofBeflft. todef cxutilN of rnjoov" 
tokft drjf Bdkv JMih Ol, wtae 
cMtok<t«1niaa of ABB at n c9Bi]ei)7 
boRd mailt9)bi.XL TtoBV lie te- 
IfwWQ br BMV f«MAD9 aod ko- 
pnaiakaty IWp toa b y te wi. n't a aa. 

kkd poUfkikXi ate iHlUnf 



Ufa liart^ jyatf^ be (WPUkl mitO' 
Mait to ekto to ai ln<l B| oev ndoe bet 
wfl tni2je|n8rik a&^ninbbkki dt* 
Itfcd uiictoekje ef Cttcava A 
RveniaBd'kMked code otttiponto ca^ 
tola rtieaeed b Qeaanjr b bto PURkvy 



ittuu. eu 



pcrtton bA )Dte •M lAlk ekio ttd OU- 



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fl ebpaft lo 

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COf ^ neoM, MM HH 
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nLusa 



pef^kjBDR HO weiteol tai M0 
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oki (ftoiTitk. a*B. utoaiw «a ttt In 
Nfv |u«ebbe ar 6k Pcdick-i wMfeBA, 
Bdutd 



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aBtteatotoof nata aeu — kaow ifl 
iMd vtdM rtdt Ui l^ycto. wimrfu a 
MR (a tba haadMsi. aeoadfta a a 
ibi tdqpiiltf kr Mvtik Btkk nd Be 
PtomaLte Ub, M:. fiimA to 
(90 el < 




n^^^^.o.,r>4>. ^. ^r,!.^. ^^,,^r.,y QpcLiRagflf t Filed 04/24/03 ^aoe 64 of 64 Paga 4Bfe#:64 



'T-3* Cost Lots Even Before Production Started 



UAfi , cw to itti. Hooeaii lett QM 



« 6kH fit Utarfr Ano- Oae (Men 
nte el (kt Fvaori U •rtn bisuti u Wr. 
iv« M ^Obmb fid BubnlB,' 



Ok* ikku ud wx rsrad a^im k 
■«D tf nt Mteci. On* c; tte MM -Mkitii 
d Item vu 10% bf lu it^ ngbti to 

Skitf Otraiga Pktvit, i VCVtt U9Sa 

ki fltKti <te 'RA«te* tcda tad 'TiAc 
tkiCML' Outfco'i prt«tinli. Uctirt. 
Ebxw tsd Itqvtd la Ud faBi«kl 

rtghv U» Wttitt. Um . Rbsw nd 
\ift}ej) iMw iiitf Hfaicndt&.ciiiicfm, M 
bad «e(tM (Or M«; M tattowtnr 
oo lunott- Fir* 8»od tatn.* Mr. CMR- 
im afTMtf t» wrUa ud <nd I ttqeiL 
But Ui. Hurt Nta cMnAd M nof «l 
dM MqLfl ilititf- ttfi*a IS pgr 
her P arttieir tft bm* piodwfr «r 
Willi bawiM *Tmi^nat i^Mpm 

0» nita t9 Mr (otwt m^mIsu ur. 



Butfi^Mt-^ Mr. pii rut Mm 

Ikttim ta HD*! Uaf.tHit M liisi lib 
tkn-t IIR Ub; ti OWfta ciDtd ^OfOi 

mir OH tec»« « ei4 dMJc Mrtor 
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|»43i'^nii* rtpuaUu ud • mem Or 

BMIOf lilt liU ouoUt Ul MOfikA 

from CtiatC9*t nwiyfkjtpl ffcM«i«J tfi 
cart 

Tbft ton asat Uk tvOMiA pviscn 
4)tf fiu m Mfi » racui M9«i fiiut 

<9 -Hit ftrateui&Krkfc n»a*.<y >>* 



Bttv «A Icr BM ta (M tmitci tt 
cf-L Ito lii lor oOloi. Oe i«l 
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•T^'«Bt KtB IM Mir ow (Im* 
19 to (toutt or dUDfttf* tbi omit. 

T»a taait, <t< 1^1 ty i mtiui od 



■In » im Wr. tttovmmir to 
«W u iMyvwl bMm lU vdV 



Bush to Send Speddl Envoy to Mideast, 
As Cheney Begins Permm Gulf Trip 



fnoii\ pavTV c ^ c iyiay Oil na bad 
uflMbtau Aid fUktd 4i( IB nmte 

itM uhtc 



uSKlkBs(Uft|knttiulSB» ri|k« 



t pxn 

taaa^{A^I» •itouHiin«^«a&- 
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-om- Kr. 

lAM teni aa] Jkaa Kvaiada. to 
tioli ■! tCltoL llHqr in «- 

tt T-r tor 1 Mtf H BD toDHoQ. 
utoe^tnd Von. vuta Ud nt* 



Amdd SckvoarteneggET, whom T-3 *proihuxnMiij is 

vowji of the tcT^ — and ihef27miZlKm pay— that 
the timihadcometoga cyborg 000^' 



tti U tarIMb M H «OQt Ol : tiMi't 
kitf I ^ daor TOW b Be 
fMMttr ti4 Min «8ienr. nd kafenta a 

■ytoLrttolntfirbain a lu 

aolpt-tttfMlV 
tlsw ted caM to |D frtarf tcii». 

it tt» !«» vUcfitiV tfadtai 
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«f«Qll tak aei ataa te 7-r mt^ vr 

MM tocaittrtsiii 
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tt»tt4»Mto*tia l!> ft ta^jn 

&ta Qd pndMr^ Ma. 

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Q» ItellMllwa^toja^ bM«M^ 

ter btm^wR iTa« ttp ie«i taaer 
BoMir 19 u UM ItoM, (ki mna aayi. 



Oew aftM M ■ Mdu Bui ertitf wtB M 

HLBDlCnoi^inik Ftca mfttBt anoitaMUAkitedifttoMfvkfttm' 

D(4<»«Hy MtLadfTftxtiiBftPtaita* •litlirQk|»dKniieo,U«'«lUa«ttt 

<M U1» to dlMB Qd ««r w Wm^ Mr Dttatnny^ttoil^' 
Hid. Pntldnt^) laid tell aw MSd- AdaddNUHleo «feciata fttr 

ipadai esvvy AbUioiv tbdi «• at* clftta»4il1ti.Cbd0tr»lDdaUMrav»ei 
dftat «lM9t to ]wi(CUn yatct taOa ta>lMdt vUU^icUatciliM 

batwK* ItTMl aad tka PaktdvUiift. Inq. ^Vi* H i» *t»ck la ikaat l» 

-TMV«M4ltftt4»k*l a^«ll«ie(ft t(«ftk «d< «ia AT «W IMM tttt 

■umtaatuvkiit <ttpia(iia,An^ oKn(it».*l«««ttfyoritfiaceua^ 

«idIiraiSd,uaiM iTBli aaM.iitmttf toIn4.li«awdKBrtti 

' to ItaA ^iTaB^ fBm«l^ta«i6Mvatttdtad&rlcr. 

gws ad wWtf i^Hk M as 'Udd o( MrU" lUrvsUxini 

ftiAafleawWMt'BixtptWWeh 
Mfkd t0nd>7«UdailcMtttD keep fr**- 




fftftwl to Usu ol fnytKM ft Oidf- 
niaitutoi la KI9 irfittoa. 



i» '.lift ntttci to ^atiil ffltcb Kiwi 
ii cfCBcd OKI Oil jjy i koUli^ MdktM 
thin. 'Ttomtaittr r «fu dnaitcr Bit, 



tu. beoi oOct nd saoi M«a. 
nil ««)t noan l9 ■» QMitt 
ni^ (bfitr III iBtfnf ef 
Mr. Kaaw^Ur, lul aoM w mm 



. Uja_ 

V vdd r<toM br asnr TuKna-Qie a> 
dld^ lz«t<cpcBdbff iBdM k to basftf 
n«t9 pranidBp ta Oi s<»^ttto. tei 
mita, * m atOtt to *• T^naJpUBr* 
Inaduu «u e aiMt to bt eff 
to tdiitmpicy sfit. 

Kr ttpd. aa tiiafla. tartod » 
ductioo CMitiiiji Chn{l Rttwd 4W 
«di invito ncfa as *tftta' atl 
-ntmL* Mr Kcnat lAcr Ite (^Gtodt- 
MAi, tMsn* ft pn^ieer el rtiiaeun} 
Pfcti ct^baii giiii ladflrt trttigttoiCQ't 

CMt^MBdO^ Jlfld OWfOtttt IWf l Kt 10 
QtvcwUas In CM-DMi, fif. KMf 

Mr vnju «t cmain. rMMi 
&S FMMna ifbr Ifr. beiaM beck 



^ntf vtXI IfSMBflM ftB I)quitfftl&V 
bvi or (^fdfib. Ml. ims diy9 Qia «^ 
nuK price na Maad H hiir d irtitf Clio 
Diapaiiltar rtrtu to Ttonte. 

tar i* ind cartftfeily iBdg'l ■»! to pel 

WdPjcmoi cof oeiliij amibaelMa 
totUtopU Ud i« to* Kdltai afiar lfir«. 
dtfi IttM « ft lUMttftdt rilv. 

Mr. VktBft waa >ddla*t BJ Mftfitot. 
Tliat m&J^ ha cia«d Mc Ouatran 1a 
ateima cvd bfvi aM, M b^ a»K 
U» tfcidtrnr Oft DftiQswDL 

Iba atoa ^ ekB«.- m dtmUr r^ 
fpeeSM w^, Mr. ^Hm nyi Ur. <^ 
ra cotfol ba iwi^ tor avnnt. 

wioMfilindMr Cdnina teartito 
.to i«)l4a do* CD U9. u ftat Knan. vih 
)&ft tad laa^r ft««« ncatoed b tin. 
thalr imntt ki Iba -TBWinttiC Alkti. 

Cktaana fuif baotdortAttetWii^ 
aeaaiB «ub TwarllMb Cwttf fvt. 
itHTft bd «M CUsf oa ok Tl. 
toad*,' to lartft • da* » -T^'Pw •»» 

Kntrr. ni}Qft nd Eimt. 

Jwndft Olev ^ AdSA Ontv 

lbai« w 00 J)ift, Ibtod vta na nerte Igr 
At.' Mjit B fl iseandiu tbe iBRi* dM^ 
«aa of TWMh Oottir 



m'l 9ilf -of ^Dtttl uiiJiiia to elur dto 
•eidei HUktodMpTSa p«JtdUbid 
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fif to toka (■ Ifaa rW«( prtW 9 toW 
hr pnddcUB. ittBR VIM nd IbBir 
ui0f tottevacdd nui At<^ ftOar 




«g ito* to** ft ' gg>_' <'^ ' 

pmt a od « -M' mouft. 

ftid (hor Miin (o aaitaia d ib« 



. tar ttw wto 

pftftttt to tbi prwitcttQti. U»- ntnd 
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to, ttd ptdadv M ifotfitar « nfi- 
ita. Uttnadto pto « m iMtoB OKI- 
ttiei bt fer Uiioil tft bntp idiM 
ft0l tfd iDtoiln QidSte, And MatSid 
fWfca «m » Fat luaytn, teufn<i.<0«> 
ptfldMi baa^ dad Sftiodnr Odtpa. b> 
ttoaay -a t it t n n 1 a iitoji l at a qaa at 
vndhc0i 4d3i di z^iHQ dad dMH^ 
BUi. Ibc UUI bb fn r via «to» to 
CTU mlWt-'dKMaiii otoi did 
•toM dd budfd. 
h Ob C9i. mnff 9tL nd Bao 

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M tvttatetotfbc ndldMj^toairdto' 

cam; toMmt&sf)'^ ^mj tted 
vtt. toat^ ^ 4nli iw»a bm 
d0Md to wad Bi an^Mitaitor *r J* 
df a «ll ■ aid) lODtjr- 



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MikrVitb lUwa* dAtU^aabid ttdt 
b MBit adMdtiaafti biMMia Old Itott 
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M II ^^n flt^ CK^iftif tbimkkdlr 
bdktta bH tttttlM,* tsduAiv Untl. 
Obi too« mdjr to laooasa ujka. 

Mr, jBib CtBUcHdd ttftl "Qara an M 
aaamaaaa- Bte tte iBldilae «tU m. 
tt whl, tdt th a ii M |trta| to pcaimt 

Pm 1i Revufiif . Vr. Oitori b1» 
ttOBVQiai n^taaiall ml ai cirty itc» to' 
•inJ I. rati pawa proem, t*atojttft|o»- 
}vsm IB to tngjmic Bsirk> osrod- 
aaatoimttdd by mraetordf Cann] Id- 



v«b(kailKtiiB|BDlito9ftcdM Ttmn 
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vtailMtM mud KhMar Ttov Biiir 

idMSb.' 

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ti Oa kHfiD d^Wtttloa tad bivcr 
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adniad« ^ t^x^ I »f » >^ 

nte* Utvida ddpan br tJ J. ddtpq to 
raq lad ft nsra dtfTiadf* fqh by iha 
M adtoUBTinae to UdJi «ut 



IxUjmdi 
viyiaitbi 



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KncrMQ VfaglitrtoitiEtoits. AiBDBon 
anlL4 



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btnadif pnmra to (%4apcB la iba 
paftca pfBttm icnitoa PnaMiu Bttdt 
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du dwdma ttBl BtHMadU ptaTVtd n 
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(ka^ Uftq'idodtiT, dvbkdl Bad WafciV 
tat nauoad ud 0» toilttatte aOidta 



wdtojiaatf 



tfd««rttclttor«ftieetad 



^(b( (dtdrtJ idpiddidQ iDd tlBbtoaUr 
lieai aa afti>iaht t«d a^ttla^a tuSk 



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to SHi Kdlbau Mtly 
disiMiiMtt Ttay 



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^ ^^rit 

Uto Aj«sw li toMftly atdxd iDd^ 
^MJkawvaiai.* 

Ma c*a to BilaK Vtta Ba H/ .tbiod. 
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kr«ad«id (baaedttaMM. 'A ««Jtt» 
Bona II od B iBbdl.* bbtna. tlUn m 
bdCBoi Ittdft "ftiidiiiiir U M msOk 



TTvap&CutAeAiea(^(dQQBdaHoldout$^ 
As Officials Say Assaiih Could End Soon 



Pension Move Mars a European Executive s High Standing 



Jdadd tb» bdftxtt cf QBPcit 0^ tad 0(0- 
ffvl Jddttn Qkp. tf • btpffld «t d oad* 
ctfttl E««»ra ddd paFMBO id ft OJ. 
tad Bfltilh ttj^a d cgpofna iwu ^aBa. 
«tdk cKttor dudBKTs tiid bonrdi tod 
en rail orviam.. vta rtttaOf. dr. 
ftescvlt a^ 4 dtnetar df 0it orper 
dataadtfwinuQ d ttm^ kdnltoi h- 
ftotor dfii lb| ttntiUncd imp 
nfiad V '^BAo'ftiHJtedMfv tosi^ » 
ranakn dAinuA d tht dr« aOfiaaf 
Aditfaoea PLC utd a dtneiar ddM. 

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fdd daddaMatoi to sn 4x1 nttr 
tt\ auKUa H» Irataial bdaafy. 
(dlkad abk paopia «f tb la^ tad 
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t ad>aASB1dnc(ifft|ft*B 
wtto ^ovtr. Tba nocks «r d^ idd »aa 
AfiS -pradKad Tdontf aMrifUg an 



Ttaity Aztof dr. Oovavin U KMll tt 
fXy nu <m9ii>qr bvamt «Aa d !»■ 
npa"! BMt i«9«ctffl iKdcfl to ft OM 
taatb «iaid *Jkfi8. Tha D««i&f Qtodx.- 

^ 1 A:ro abovtd 

I sqpa am On 



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tMdanodtKt.kaotdciiir a.'iut^ hli 



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ffli-Bicdticf d ilGlid ^MidiBi vtdto 
teaetv dnar OM to toet^ flurtcK. 

')iL BdfMVDdEOM tobelcientraed 
toroiuaitida ttultiis ]dd-B>3t£ vtik 
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^ tiafttoat mwi ft^drt Ui pautBO ir- 



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na baU lor yt. BiimVt% pcqdaa 
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d AtOddJdia idM douaaey OR Qd 

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dWdl ttttd Itoea 1ft aa «all ba 
&dd«d N aom la EKi aadml 

adkadta^ 
f<ktda 
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Matt« OH am d dmriUtoi, ft aadv da- 
diaa adddft] AM. ^ tit ddtodtflf u ar 
ery dftji,- Qda Bflldd] Bfttd. 

Ifcn Oftfl a dsaa in^ attack batl • 
oMir« dnM pcuftati irf ai ^ada and 
fUDtoa misUMM yntcRM Bd MI 



noitoa mdtiaot yiMlw Bd B42 
bonban drOlyCd practAOQfiddad 
MMh« to abai btoi ivparlM diaatbad 



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bOfiiatditeooodicl ..a>lhaMtoyprtd« 
totoo.* ba Old. lit Mcitei ttr ndit- 



ASS eaaadhuaid board Mmbn tty 



Tricks of the Bottled- Water Trade 



ffia. Iba l(tlt7 Wd ccdB loflid] rddaltnd 
for ak^tdte )tr. BftiaeiO^ cKtaaBia 
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tlW Jds;MLKMKMbfr.DOtEtIDato 

am a> ui<itciia » « ft^ ^apott Sb. 
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tv£a attb toadf^ d Ut^ tMB» 
niUac*. Vaebm 9 laaiBtod a Ma <^ 
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di^ new. 4f» wt MBCPt ry hty ^ — 
uavacap^ b> Al 



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. iPBKdTBgad dintattaca Dm- 
tn t& tba nctoa, owTvudBf i Koaber 
domMd 



A iBDkiiBtoi fa- Qw 04. £«strd Cbn. 
toftcdb £bd)L na. Atf ABV^Cda Jbnae> 
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PiOeplut or Pua^' 1 Had in ban td 
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KUb to baH myty jaa tk rid riSI tt 
tao^Midi or Quda ^jottliid'^ Bcn dm 
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ivdstna-ttQ- 

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outto d Id toeajml^ 'CkeieiMn ofi- 
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piddBiammoL 

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tor aipmd. aoadftfiT Itviftti do. 
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M ttodd Im iifcad Ida bond to nftoir 
todpadoBOt Mr. UdUil.Dd aanMv as 
CSd. 



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mtati Mft Mietti t.dfcattecifa ba- 

la**f*l* totJi^iH^pti<^t1iiyan 

ibidcidtylbaa 




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wa ttp^ bade tout.' toft ft Kr?ir 
vtao ^ bf e« btosl -Wm' ai ibi 
Wtoieri ftaia&fi lEtanei iiMfB kMni 

pttoaal bouiad wdtr. AH Ibn.^dlir 

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<ai|dlpdfte atmy< ebeqie*<ancr.' 

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tftfl Mctnao.-' ityi Bait7 Wm. a 



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tocdlsdeBOadlvakft. At Ataitoadr 
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car< it't aiiy My W to MOtdliaw, tod 
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triad to datoa tke-ttsbfea'a Cto4e*->ti 
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water. Mm (|m «fd(ir ittnad wCUi m 
m. ddTM borua d cas wata- ItsuM, 
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iddea. «t» dIdiMa to wan Qm 
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tinftditoiid«di1fnftdydade»afi 
l^fttm aaetaa le lanplfieftM.* 



ami didtoX iestodte tofaodo ate ft> 
itoidtd tba BMUar. Itito iaiK7 ini 
baia, bacaiff AQB tt*! rami gaato- 
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niBdsr kQ4 OKk iidat ycat Tld 
ttdty d AA^ asjot «Uf . Arpq Ccft^ 
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•acM at9 UadaAl M tdw qi 
(be C±D id> w 9daii7. «klR«ii a fl|tl. 
At boarf aaatti^ m BqlCb «• Uty D 
tad Jdr m Mr. Etoer (raaad EOT B to] 
aceovibf . Ml Binn!k, ^ Etoan- 
«Sn[|av e«y (esddd 10 be mttiip^ 
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ftbatflr fi*t laa ibt dttoSi.' • 



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ottn d ki Bdiftsii:^- Ldwytrt tor u 
^BW Bttattaty . adl BiddBcqtBug 



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MdODrf (bdMiata^twiaiMft'fe 
Bdtobtton ^tdb'.btokaaidne^ 
(hB tftttfC It taii^ to t odito d dxytj 
■MaMbrd-iMMaB.' 

Tld IWirtMiMM d aa bdlto lai (bd 
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t9 etoWhto^ ecsaiUlr ftiidMer Mai 
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ItbKttaAi 



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ft ndt BO iftit aypaan toba tba (t 
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